Study on enhanced sound
requirements for mopeds,
quads and replacement
silencers of L-category
vehicles
Final Report
Written by Papadimitriou, G., Ntziachristos, L., Steven, H., Dittrich, M.
October – 2016
EUROPEAN COMMISSION
Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs (DG GROW)
Directorate C – Industrial Transformation and Advanced Value Chains
Unit C4 - Automotive and Mobility Industries
Contact: Andreas Vosinis
E-mail: [email protected]
European Commission
B-1049 Brussels
EUROPEAN COMMISSION
Study on enhanced sound
requirements for mopeds,
quads and replacement
silencers of L-category
vehicles
Final Report
Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs (DG GROW)
2016
EUR 2015.5724 EN
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Luxembourg: Publications Office of the European Union, 2016
ISBN 978-92-79-52219-2
doi: 10.2873/054474
© European Union, 2016
Reproduction is authorised provided the source is acknowledged.
Table of contents
List of abbreviations and acronyms
6 Executive summary
8 1 2 3 4 5 Introduction
25 1.1 General
25 1.2 Current state of play
26 1.3 Study approach
27 1.4 Structure of the report
27 Stakeholder survey
28 2.1 Organization of the public consultation procedure
29 2.2 Processing of questionnaires and analysis of responses
36 2.3 Summary and conclusions
68 Amendments to UN Regulations
72 3.1 Regulation 9
72 3.2 Regulation 63
80 3.3 Regulation 92
85 3.4 Further amendments proposed for Regulations 9 and 63, not yet adopted by GRB 88 3.5 General comments and recommendations
89 Cost-Benefit Analysis of additional measures
92 4.1 Context and approach
92 4.2 Methodology for the CBA
93 4.3 Input data
98 4.4 Results
106 4.5 Conclusions
111 Final conclusions, recommendations and future perspectives
113 5.1 The need for enhanced sound control requirements of L-category vehicles
113 5.2 Amendments introduced to UN Regulations
114 5.3 Costs and benefits of the proposed amendments
115 5.4 Directions for follow-up work
116 References
118 Annex I: Questionnaire that has been used
120 Questionnaire version A
120 Questionnaire version B
125 Annex II: Filled in questionnaires received
129 Annex III: Collection and processing of responses
130 Annex IV: Amended UN Regulations
131 5
List of abbreviations and acronyms
ACEM
The Motorcycle Industry in Europe
AMI
Acute Myocardial Infarction
ASEP
Additional Sound Emission Provisions
ATVEA
All Terrain Vehicle Industry European Association
AVERE
European Association for Battery, Hybrid and Fuel Cell Electric Vehicles
BMVI
Federal Ministry of Transport and Digital Infrastructure (Germany)
CECRA
European Council for Motor Trades and Repairs
CEMR
Council of European Municipalities and Regions
COP
Conformity Of Production
DG GROW
Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs
EC
European Commission
EEA
European Environment Agency
END
Environmental Noise Directive
ETSC
European Transport Safety Council
EU
European Union
EV
Electric Vehicle
FEMA
Federation of European Motorcyclists' Associations
FEVR
European Federation of Road Traffic Victims
FIGIEFA
Automotive Aftermarket Distributors
GRB
Working Party on Noise (UNECE)
GRPE
Working Party on Pollution and Energy (UNECE)
ICCT
International Council on Clean Transportation
IMA
International Motorcycle Alliance
IMMA
International Motorcycle Manufacturers Association
ISO
International Organization for Standardization
JRC
Joint Research Centre
LAT/AUTH
Laboratory of Applied Thermodynamics, Aristotle University of Thessaloniki
LDEN
Annual average noise level at the dwelling façade (weighted for day-evening-night)
Lnight
Annual average noise level at night (sleep disturbance)
NORESS
Non-Original Replacement Exhaust Silencer System
NPV
Net Present Value
OEM
Original Equipment Manufacturer
PTI
Periodic Technical Inspection
PTW
Power Two Wheeler
6
RESS
Replacement Exhaust Silencer System
RMI
Repair and Maintenance Information
SMEs
Small and Medium-sized Enterprises
TA
Type Approval
TAA
Type Approval Authority
TS
Technical Service
UN
United Nations
UNECE
United Nations Economic Commission for Europe
VPSD
Informal Working Group on Vehicle Propulsion System Definitions of the UNECE
Working Party on Pollution and Energy (GRPE)
7
Executive summary
Project Framework and Objectives
This is the final report of the project entitled “Study on enhanced sound requirements for mopeds,
quads and replacement silencers of L-category vehicles”, related to performing due diligence on
noise control regulations for L-category vehicles proposed at UN level before considering their
accession into the EU type approval system. The project has been executed under Specific
Contract No. SI2.709397, Service Request 446/PP/GRO/IMA/15/11821e under Framework
Contract No. 356/PP/2014/FC LOT1, EC DG GROW. The consortium consisted of TNO (overall
framework contract coordinator), LAT/AUTh (technical coordinator and project manager), HSDAC,
and TÜV NORD.
The “L” vehicles category consists of a rather wide and diverse range of vehicles, ranging from
small electric bikes, to much larger three-wheelers and quadricycles used for the transport of people
or the transfer of goods. The engines utilized also range from low-speed diesel engines used in
micro-cars, to high specific-power high-speed petrol ones used in applications like sports or supersports motorcycles. As a result of the diversity and the variation in technical specifications, a number
of UNECE technical regulations aim at controlling the emissions of these vehicles. In summary
these include:

Regulation No. 9: Sound emission of three-wheeled vehicles (L2, L4 and L5 category
vehicles)

Regulation No. 41: Sound emission of motorcycles (L3 category vehicles)

Regulation No. 63: Sound emission of mopeds (L1 category vehicles)

Regulation No. 92: Replacement exhaust silencing systems (RESS) for motorcycles
Based on the EU vehicle classification system, the equivalencies in Table ES.1 apply (Regulation
(EU) 168/2013, including corrigendum of March 2013).
Table ES.1: Equivalence of EU vehicle classification and UN Regulations.
EU Vehicle Classification
UN Regulation
L1e-A, L1e-B
63, 92
L2e, L4e, L5e, L5e, L6e, L7e
9, 92
L3e
41, 92 (replacement)
The main objective of this project has been to perform due diligence on UN Regulations Nos 9, 63,
92 before considering their accession into the EU regulatory framework. Regulation 41 is not
considered, as this has been already acceded by the EU regulatory framework.
In meeting this main objective of the project, the following points had to be addressed:

Understand the wishes, demands, and requirements from different groups of stakeholders
(type-approval, market surveillance and enforcement authorities, concerned citizens,
associations, industry, etc.) in terms of further noise control by L-category vehicles.

Identify any flaws in the test procedures proposed by the relevant UN Regulations that had
to be addressed, propose improvements in those procedures and ensure robustness of
testing.
8

Enhance regulatory enforcement and market surveillance provisions in the UN Regulations
and assess existing or potential anti‐tampering technological solutions in the field of sound
emissions.

Amend the Regulations in order to facilitate in use compliance test of vehicles in motion,
which are more efficient than tests of the stationary vehicle in the vicinity of the exhaust
outlet(s).

Examine the cost‐effectiveness of the proposed improvements, by performing a cost‐
benefit analysis.

Retain international harmonisation on the regulatory front.
The main achievements of the project, presented in detail in the current report, are the following:

Collection of data and opinions on noise from L-category vehicles, through a public
consultation with key national, international and regional entities and associations from EU
and non-EU countries.

Conduct of a cost-benefit analysis on the need for additional regulations, focusing on
environmental and health benefits due to noise reduction, and associated costs

Technical assessment and proposals for amendments to UN Regulations, submitted as
working documents to GRB, discussed in detail, reviewed and justified.
Sound emission from L-category vehicles
In order to collect the views of main stakeholders, related to the L-vehicles noise, a questionnaire
was formulated and was disseminated to 123 individual entities, categorized as follows:
 Social partners
o Countries (i.e. ministries of foreign affairs, national permanent representations to the
EU), cities (i.e. local authorities, municipalities, European cities networks), citizens (i.e.
European consumer and other organizations)
o Motorcycle (i.e. drivers) and noise concerned associations
o Environmental organizations and institutes
 National authorities
o Technical services and type approval authorities
o Departments of transport, market surveillance and enforcement authorities
 Industrial stakeholders
The questionnaire was formulated appropriately for the different categories in order to make it more
suitable for each specific stakeholder category. The aim was not to collect general information from
the public, but it was rather more focused on responses from entities which have a certain
experience in the area of L-vehicle sound emission and response from city and regional authorities
than individual citizens.
Based on this invitation, we managed to receive 66 replies, out of which, 44 completed
questionnaires. The share of entities that replied to the questionnaire is shown in Figure ES.1.
9
Figure ES.1: Filled in questionnaires received (44) organized into groups.
The main findings from the analysis of the questionnaire responses, can be summarized as follows:
 Noise perceived from L-category vehicles is still considered to be a significant problem for
many European cities and public authorities. The problem is more intense in urban and rural
areas (compared to motorways which are considered as less affected).
 Most of the perceived noise is considered to come from tampered vehicles and especially
motorcycles; however, mopeds and other L-category vehicles are also considered to
contribute to the noise problem.
 The main noise responsible are considered to be the drivers who tune/modify the exhaust
system or use special silencers on their vehicles (e.g. young enthusiasts enjoying in
producing as much sound emission from their vehicle as possible especially when driving at
night).
 Concerning the regulations, the main problem is identified as the lack of adequate market
surveillance and enforcement of regulations, and less in the type-approval procedure itself.
 The majority (80%) of the participants of the survey would like to see more done towards
better noise control by the following:
o
More anti-tampering measures, better market surveillance and better enforcement
of regulations (e.g. by police control, roadside checks, more effective periodic
technical inspection checks).
o
Improve in-use compliance sound emission tests to better reflect real driving road
conditions and better check of sound emission of vehicles in motion.
o
Prohibition of defeat devices and of easy tampering by proper design measures.
o
Impede removal/modification of individual parts from an approved silencer.
o
Regarding sound limits, it is acknowledged that more strict limits in general can
help towards reducing noise, but there are some concerns that this measure alone
is not sufficient (i.e. if not combined with better enforcement in practice).
 In general, the main obstacles for effective noise control are believed to be the following:
o
Periodic technical inspection and in-service conformity testing is not conducted in
all EU Member States.
10
o
The stationary control test is not always representative of sound emission from the
vehicle in motion under real driving conditions.
o
There are many possibilities to circumvent testing results, i.e., shutters, parts that
can be ‘loosened’ or removed easily without the TA marking being damaged, etc.;
shadow modifications cannot always be checked (e.g. internal exhaust
modifications).
o
As silencers are easy to replace (original to replacement unit and vice versa), often
a racing silencer is fitted for normal road use which is temporarily replaced by the
original silencer just for the periodic technical inspection.
o
Complex noise control procedures are not always easy to be performed by police;
moreover, there is often lack of staff, budget, resources, and equipment for
effective noise control.
 Specific suggestions regarding replacement silencers, in view of reducing tampering and
making original components easily recognisable by test and enforcement authorities, include:
o
Use an official label on the vehicle frame/main part or an official electronic database
(e.g. available via Internet), where the legal mounted silencer or RESS is
mentioned and all reference and practical information is included (i.e. vehicle
manufacturer, vehicle type, trade name, engine capacity, engine power, model
years, remarks).
o
A special sticker with a sign indicating that a product is compliant with noise
regulations could be effective in this sense, together with an awareness campaign
for customers on labelling of compliant products (e.g. similar to EU tyre rating).
o
Ensure that the ‘E’ mark remains clearly visible and cannot be easily removed or
‘polished’ out; moreover, ensure that tampering of 'E' marked exhaust systems is
not possible.
Proposed amendments to UN Regulations
The amendments to the UN regulations were designated to the two following directions:
 Firstly, editorial changes were made, in order to bring these regulations on par with
Regulation 41-04 and Regulation 51-03, where appropriate, and to better clarify the meaning
of the various sections.
 Secondly, technical amendments were introduced. These have been substantive
amendments aiming to better cover the specifications of the vehicles or introduce additional
control of sound emissions.
The most significant technical amendments introduced per regulation can be summarized in the
following points.
UN Regulation No. 9:
1.
Throughout the whole Regulation:
The term “noise” was replaced by “sound” or “sound emission” except for background
noise in order to bring it in line with other UN Regulations (e.g. UN R 41, UN R 51).
Consequently, the term “noise made by” was replaced by “sound emitted by”.
The letter “S” representing the rated engine speed was replaced by nrated in order to
prevent misunderstandings.
11
The symbol “%” was replaced by “per cent” in order to reflect present practice.
Fractions like “¾” were replaced by percentages like “75 per cent”.
Whenever the word “speed” is used non-specific, it was specified whether engine
speed or vehicle speed is meant.
2.
Paragraph 2.1.
“as a technical unit” was replaced by “as a technical unit of a vehicle type, falling
under the scope of this Regulation” in order to make the text more comprehensible.
3.
Paragraph 2.2 “Vehicle type”
A new sub-paragraph 2.2.4 “The electric motor in case of a hybrid electric vehicle”
was added in order to cover also hybrid electric vehicles. The inclusion of these
vehicles is necessary, because L5 category hybrid electric vehicles exist on the
European market.
Sub-paragraphs 2.2.4 was renumbered to 2.2.5 and the text was modified in order to
make it more comprehensible.
Sub-paragraph 2.2.5 was renumbered to 2.2.6
4.
Paragraph 2.3
The reference to the ISO standard was updated to the latest version. The symbol Pn
was added for easier reference in the text and in equations.
5.
Paragraph 2.4
The symbol nrated was added for easier reference in the text and in equations.
6.
The existing paragraphs 2.3 to 2.6 were renumbered to 2.5 to 2.8
7.
Paragraph 2.7 (old 2.5)
The added text was copied from UN Regulation No. 63 and will improve UN
Regulation No. 9.
8.
Paragraph 2.8 (old 2.6)
“Kerb mass” was replaced by “reference mass” in order to reflect present practice.
The reference to an ISO standard was deleted, because it is not necessary. The
symbol mref was added for easier reference in the text and in equations.
In order to consider also hybrid electric vehicles, the following indent was added:
(e)
9.
the mass of the propulsion battery, if applicable.
Paragraph 2.9 “Test mass”
“Test mass” was added to the definitions in order to make the text in Annex 3 more
comprehensible.
10.
Paragraph 2.10 (2.7 old)
“Maximum vehicle speed” means the maximum vehicle design speed measured
according to ISO 7116:2011 for L2 category vehicles and according to ISO 7117:2010
for L4 and L5 category vehicles.
The references to the ISO standards were updated to the latest versions and the
existing text was modified in order to also cover L2 category vehicles appropriately.
The symbol vmax was added for easier reference in the text and in equations.
11.
Paragraph 6.2.1.1
12
The following text
“If the vehicle has user selectable software programs or modes which affect the
sound emission of the vehicle, all these modes shall be in compliance with the
requirements in this paragraph. Testing shall be based on the worst case scenario.”
was added to this paragraph in order to prevent loopholes in the sound emission
requirements.
Furthermore, requirements for hybrid electric vehicles were added according to the
EU Directive 134/2014/EU. This is necessary, because L5 category hybrid electric
vehicles exist on the European market.
12.
Paragraph 6.2.1.3
The word “measured” was replaced by “determined” in order to make the text more
comprehensible.
The sound limit values were put into a table in a new Annex 4 for alignment reasons
with other Regulations (e.g. UN R 63 and UN R 41-04).
13.
Paragraph 6.3
The header was replaced by “additional requirements” and the more specific text was
moved to the appropriate sub-paragraphs as headers. The added headers make the
text more comprehensible.
In paragraph 6.3.1 the word “easily” was deleted in order to strengthen the
requirement.
In paragraph 6.3.2. the words “or electronically” and “rider selectable” were added to
cover not only manually adjustable multi-mode exhaust or silencing systems but also
more advanced electronically adjustable systems.
14.
Paragraph 7
In sub-paragraph 7.1.2. “Technical Testing Service” was replaced by “Technical
Service responsible for conducting the tests” being more comprehensible.
15.
Paragraph 11 Transitional provisions
The sub-paragraphs 11.7 and 11.8 were added in agreement with
ECE/TRANS/WP.29/2015/59, which was already adopted by WP 29.
16.
Annex 1
Point 5. was renamed to “combustion engine” and supplemented by the sub-points
5.1 Engine manufacturer and 5.2 Engine type. The original text under point 5 was put
under 5.3 and points 6 to 9 were renamed to 5.4 to 5.7.
A new point 6 “electric motor (if applicable)” was added with two sub-points 6.1
“Make” and 6.2 “Type” dealing with information for the electric motor in case of a
hybrid electric vehicle. This information is necessary for the determination of a vehicle
type in case of a hybrid electric vehicle.
Points 10 to 12 dealing with information about the transmission were merged under
the new point 7 “Transmission” and were supplemented by 7.1 “Make” and 7.2 “Type
(manual, automatic, CVT)”. The old points 10 to 12 were renumbered to 7.3 to 7.5.
The following points (old 13 to 18) were renumbered to 8 to 15.
Point 15 (18 old) “Sound levels” was restructured to make it more comprehensible.
The required information was put under sub-points 15.1 to 15.4.
13
A new point 16. “In use compliance reference data” and the sub-points 16.1 to 16.3
were added specifying this data. The aim is to allow not only stationary in use
compliance tests but also more effective in use compliance tests with the vehicle in
motion analogous to UN Regulation No. 41-04.
The old point 19. was deleted in accordance with ECE/TRANS/WP.29/2015/59.
The remaining points (old 20 to 29) were renumbered to 17 to 26.
17.
Annex 3, the header was modified in order to be more specific.
18.
Annex 3, paragraph 2.1.
The whole paragraph was restructured in order to make the text more
comprehensible.
The requirements for test site, weather conditions and background sound level
correction were put to this paragraph.
Sub-paragraph 2.1.1 got the header “Test site” and the text was supplemented
according to ECE/TRANS/WP.29/2015/59.
The figure in the new sub-paragraph 2.1.2 “Weather conditions and background noise
correction” was deleted, because it was not in line with the table, which contains the
correct values.
19.
Annex 3, paragraph 2.2
The whole paragraph was restructured in order to make the text more
comprehensible.
The paragraph was divided into the following sub-paragraphs:
2.2.1 General conditions
2.2.2 Test mass of the vehicle
2.2.3 Tyre selection and condition
The new text for the test mass specifications was placed under sub-paragraph 2.2.2.
More specific text was added, where necessary in order to make the text more
comprehensible.
20.
Annex 3, paragraph 3
The whole paragraph was restructured in order to make the text more
comprehensible.
The header 3.1.1 “Positions for the test” was replaced by “Test arrangement and
microphone positions”. Figure 1 was moved from the current position to this
paragraph.
The header for the new paragraph 3.1.2 is “Acceleration test execution, approach
vehicle speed and gear use”. The sub-paragraph 3.1.2.1 is dedicated to the
acceleration test execution, paragraph 3.1.2.2 contains the requirements for the
approach speed and the gear use.
The gear use specifications were modified in order to align the transmission
specifications with Regulation No. 41-04. The text was supplemented accordingly,
where necessary.
14
The content of the existing paragraph 4 “Interpretation of results for vehicles in
motion” was integrated in paragraph 3 as sub-paragraphs 3.1.3 and 3.1.4, because it
is exclusively dedicated to the measurement results for paragraph 3.1.
“Interpretation of results for vehicles in motion” was replaced by “Sound level
determination”, which is more comprehensible.
The determination of the final result for hybrid electric vehicles was added in
paragraph 3.1.4.
The calculation and rounding procedure was brought in line with the corresponding
text in Regulation No. 41-04, which is more straightforward and better reflects present
practice.
21.
Annex 3, paragraph 3.2
The text was modified in order to make it more specific and comprehensible, where
necessary.
22.
Annex 3, paragraph 3.2.4.2
Figures 2 and 4 were moved from the current positions (in the appendix) to this
paragraph, because they belong to this paragraph.
Figure 4 was renamed to figure 3 in order to ensure the right rank order.
23.
Annex 3, paragraph 3.2.4.3
S was replaced by nrated in order to prevent misunderstandings, ½ was replaced by
“50 per cent” and ¾ was replaced by “75 per cent” in order to reflect present practice.
The phrase “engine speed at which the engine produces its maximum power” was
replaced by “rated engine speed as defined in paragraph 2.4 of this Regulation.
24.
Annex 3, paragraph 4 (new)
A new paragraph 4 was inserted specifying the necessary data to be reported in order
to facilitate in motion testing of the vehicle in use.
With regard to in use compliance tests it is well known from former research studies
that stationary tests are not very effective, because there is not enough load on the
engine and silencers can be constructed such as to comply with stationary tests, but
lead to excessive sound emissions for full load acceleration tests. It is therefore
proposed to provide the data which is necessary to perform in use compliance tests
according to annex 3, paragraph 3.1. This item is already implemented in Regulation
No. 41-04.
25.
Annex 3, paragraph 5.1.3.2
The references to the ISO standards were updated to the latest versions of the
standards.
26.
Annex 3, paragraph 5.1.4.2.1
Figure 3 was moved from paragraph 5.3 to this paragraph, where it belongs to and
was renamed to figure 4 in order to ensure the right rank order.
27.
Annex 3, paragraphs 5.1.4.2.5, 5.1.4.2.6 and 5.1.4.3.5
S was replaced by nrated in order to prevent misunderstandings and “%” was replaced
by “per cent” in order to reflect present practice. Where applicable, the drafting “rated
engine speed as defined in paragraph 2.4 of this Regulation” was introduced to adapt
the requirements related to engine speed in those paragraphs.
15
“to within +3 per cent” was replaced by “with a tolerance of +3 per cent”.
28.
Annex 3, paragraph 5.2.2
The text was modified in order to make tampering more difficult.
29.
Annex 3, Appendix was deleted because the figures were integrated in the
corresponding paragraphs of Annex 3.
30.
Annex 4
This annex containing the table with the sound emission limit values was added in
order to reflect present practice.
31.
Annex 4 old, Annex 5 new
Since a new annex 4 was added, the existing annex 4 was renamed to annex 5.
The footnote 1 was added according to ECE/TRANS/WP.29/2015/59
These amendments were adopted in the 64th meeting of GRB.
UN Regulation No. 63:
1.
Throughout the whole Regulation:
The term “L1 category vehicle” is less ambiguous than the term “two wheeled moped”,
consequently the term “moped” was replaced by “vehicle” throughout the whole
Regulation.
The term “noise” was replaced by “sound” throughout the whole Regulation except for
background noise in order to bring it in line with other UN Regulations (e.g. UN R 41,
UN R 51).
The term “noise made by” was replaced by “sound emitted by” in order to make the
text more comprehensible.
Whenever the word “speed” is used non-specific, it was specified whether engine
speed or vehicle speed is meant.
2.
Paragraph 2.2.2.
The proposed new text is more comprehensible than the existing text.
3.
Paragraphs 2.2.3.1. to 2.5
The sub-paragraphs 2.2.3.1 to 2.4 specifying the exhaust or silencing system, original
exhaust or silencing system, non-original exhaust or silencing system, silencing
systems of different types and exhaust system component were renumbered to 2.3 to
2.5, 2.8 and 2.9 in order to be more comprehensible.
The current paragraph 2.3, repeating the definition of exhaust or silencing system of
current paragraph 2.2.3.1, was deleted.
4.
The Paragraphs 2.6. “Rated maximum net power” and 2.7 “Rated engine speed”
were added, because rated engine speed is used in Annex 3, but was not specified
so far. The added footnote 2 specifies how to determine the rated engine speed in
case the rated maximum net power covers an engine speed range rather than a
single value.
5.
Paragraph 2.10 “reference mass” and paragraph 2.11 “test mass” were added to
the definitions in order to make the text in Annex 3 more comprehensible.
6.
Paragraph 2.12 “maximum vehicle speed” was added to the definitions.
16
The term “maximum vehicle speed” is used in Annex 3 of this Regulation, but was not
defined so far.
7.
Paragraph 6.2.1.2
The text was modified in order to reflect the situation that there could be just one
value instead of two values.
8.
Paragraph 6.3
The header was replaced by “additional requirements” and the more specific text was
moved to the appropriate sub-paragraphs as headers. The added headers make the
text more comprehensible.
In paragraph 6.3.1 the word “easily” was deleted in order to strengthen the
requirement.
In paragraph 6.3.2. the words “or electronically” and “rider selectable” were added to
cover not only manually adjustable multi-mode exhaust or silencing systems but also
more advanced electronically adjustable systems.
9.
Paragraph 10 Transitional provisions
The sub-paragraphs 10.7 and 10.8 were added in agreement with
ECE/TRANS/WP.29/2015/64, which was already adopted by WP 29.
10.
Annex 1
Point 14 “Number of gears” was renamed to “Transmission” and new sub-points 14.1
“Make”, 14.2 “Type (manual, automatic, CVT)” and 14.3 “Number of gears” were
added. The existing sub-points 14.1 and 14.2 were renumbered to 14.4 and 14.5.
The existing text in point 20. was deleted in accordance with
ECE/TRANS/WP.29/2015/64, but was replaced by a new point 20. “In use
compliance reference data” and the sub-points 20.1 to 20.3 specifying this data. The
aim is to allow not only stationary in use compliance tests but also more effective in
use compliance tests with the vehicle in motion analogous to UN Regulation No. 4104.
11.
Annex 3, paragraph 2.1.
The whole paragraph was restructured in order to make the text more
comprehensible.
Sub-paragraph 2.1.1 got the header “Test site”. Sub-paragraph 2.1.2. was integrated
into sub-paragraph 2.1.1 and the text was amended according to
ECE/TRANS/WP.29/2015/64.
Sub-paragraph 2.1.3 was renamed to 2.1.2 and the existing header “miscellaneous”
was replaced by “Weather conditions and background noise correction”
The figure in this paragraph was deleted because it is in contradiction to table 1.
12.
Annex 3, paragraph 2.2
The whole paragraph was restructured in order to make the text more
comprehensible.
The header “Moped” was replaced by “Condition of the vehicle”.
The existing sub-paragraphs 2.2.3 and 2.2.4 were moved and merged to the first subparagraph 2.2.1 “General condition”.
The new text for the test mass specifications was placed under sub-paragraph 2.2.2.
17
The old sub-paragraph 2.2.2 “Tyre selection and conditions” was moved to the new
sub-paragraph 2.2.2.2
13.
Annex 3, paragraph 3
The whole paragraph was restructured in order to make the text more comprehensible.
The header 3.1.1 “General conditions of test” was replaced by “Test arrangement and
microphone positions”. Figure 1 was moved from the current position to this paragraph.
The header for the new paragraph 3.1.2 “Acceleration test execution, approach vehicle
speed and gear use” and the sub-paragraphs 3.1.2.1 to 3.1.2.3 are dedicated to these
three issues and got corresponding headers.
The content of the existing paragraph 4 “Interpretation of results for vehicles in motion”
was integrated in paragraph 3 as sub-paragraphs 3.1.3 and 3.1.4, because it is
exclusively dedicated to paragraph 3.1. “Measurement of the sound emission of the
vehicle in motion” and it was replaced by 3.1.3 “Sound level determination” and 3.1.4
“Calculation of the final test result”, which is more comprehensible.
The calculation and rounding procedure was brought in line with the corresponding text
in UN Regulation No. 41-04, which is more straightforward and better reflects present
practice.
14.
Annex 3, paragraph 3.2.3.3.1
Figures 2 and 4 were moved from the current positions to this paragraph, because
they belong to this paragraph. Figure 4 was renamed to figure 3 in order to ensure the
right rank order.
15.
Annex 3, paragraph 3.2.3.3.2.1
S was replaced by nrated in order to prevent misunderstandings, ½ was replaced by
“50 per cent” and ¾ was replaced by “75 per cent” in order to reflect present practice.
The phrase “is engine speed at which the engine produces its maximum power” was
replaced by “is the rated engine speed as defined in paragraph 2.7 of this
Regulation”.
16.
Annex 3, paragraph 4 (new)
A new paragraph 4 was inserted specifying the necessary data to be reported in order
to facilitate in motion testing of the vehicle in use.
With regard to in use compliance tests it is well known from former research studies
that stationary tests are not very effective, because there is not enough load on the
engine and silencers can be constructed such as to comply with stationary tests but
lead to excessive sound emissions for full load acceleration tests. It is therefore
proposed to provide the data which is necessary to perform in use compliance tests
according to Annex 3, paragraph 3.1. This item is already implemented in Regulation
No. 41-04.
17.
Annex 3, paragraph 5.1.3.2
The references to the ISO standards were updated to the latest versions of the
standards.
18.
Annex 3, paragraph 5.1.4.2.1
Figure 3 was moved from paragraph 5.3 to this paragraph, where it belongs to and
was renamed to figure 4 in order to ensure the right rank order.
19.
Annex 3, paragraphs 5.1.4.2.5, 5.1.4.2.6, 5.1.4.3.4 and 5.1.4.3.5
18
S was replaced by nrated in order to prevent misunderstandings. The phrase “engine
speed at which the engine produces its maximum power” was replaced by “rated
engine speed as defined in paragraph 2.7 of this Regulation” and “%” was replaced
by “per cent” in order to reflect present practice.
“to within +3 per cent” was replaced by “with a tolerance of +3 per cent”
20.
Annex 3, paragraph 5.2
Sub-paragraphs 5.2.2 and 5.2.3 were added in order to make tampering more
difficult.
21.
Annex 4
The text was improved to make it more comprehensible.
22.
Annex 5
The footnote 1 was added according to ECE/TRANS/WP.29/2015/64
These amendments were adopted in the 64th meeting of GRB. In addition to that is was
proposed to add powered cycles as separate subcategory in order to align the Regulation
with the existing EU-Regulation. This proposal was discussed in the 64th GRB, but will need
further considerations.
UN Regulation No. 92:
1.
Throughout the whole Regulation:
The VPSD decided to use the term “RESS” for “rechargeable energy storage system”.
Therefore, the term “RESS”, which was used in this Regulation as “replacement
exhaust silencer system” needs to be replaced.
Since the title of this Regulation implies that it is dedicated to non-original
replacement exhaust silencing systems, it is obvious to use the term “NORESS”.
Consequently, the term “RESS” was replaced by “NORESS” in the whole Regulation.
The phrase “motorcycles, mopeds and three wheeled vehicles” was replaced by
“vehicles of categories L1, L2, L3, L4 and L5” in the whole Regulation in order to bring it
in line with the scope. Consequently, the phrase “motorcycle, moped or three
wheeled vehicle” was replaced by “vehicle”.
“with regard to sound emission” was added in the title in order to be more specific.
The term “noise” was replaced by “sound” throughout the whole Regulation except for
background noise in order to bring it in line with other UN Regulations (e.g. UN R 41,
UN R 51).
The expression “exhaust system” was replaced by “exhaust silencing system” in order
to make the text more comprehensible.
Whenever the word “speed” is used non-specific, it was specified whether engine
speed or vehicle speed is meant.
2.
Paragraph 1
The word non-original was added in order to make the text more specific.
3.
Paragraphs 2.5 and 2.6
“Falling under the scope of this Regulation” was added in order to make the text more
comprehensible.
19
The text in paragraph 2.6 indent (b) was modified in order to make it more specific.
4.
Paragraph 2.7
“Rated engine speed” and the corresponding footnote was added.
The term “rated engine speed” is used in this Regulation, but was not defined so far.
5.
Paragraph 3.3
The text was supplemented in order to make it more precise.
6.
Paragraph 6.1
The text under indent (i), i was moved to a new paragraph 6.3.1, the text under indent
(i), ii was moved to a new paragraph 6.3.2.
Both texts have been updated to become more comprehensible.
7.
Paragraph 6.2
The text was modified in order to make it more comprehensible.
8.
Paragraph 6.3
A new paragraph 6.3 “Additional requirements” with the sub-paragraphs 6.3.1
“Tampering protection provisions”, 6.3.2 “Multi-mode NORESS” and 6.3.3 “Prohibition
of defeat devices” was added in order to ensure the same level of stringency for a
NORESS compared to UN Regulations Nos. 9 and 63.
Furthermore, sub-paragraph 6.3.4 “Additional sound emission provisions” was added
for NORESS intended for the use on vehicles that are type approved according to UN
Regulation No. 41-04 and are subject to the ASEP requirements in UN Regulation No.
41-04 in order to ensure the same level of stringency for a NORESS compared to UN
Regulation No. 41-04.
The following paragraphs in paragraph 6 were renumbered accordingly.
9.
Paragraph 6.4.4.1 (old 6.3.4.1)
The first option with a reference to paragraph 3.3 (d) was deleted, because 3.3. (d)
does not exist.
10.
Annex 1
In the existing Annex 1 the following header was added:
“Part A NORESS for vehicle types approved according to the 04 series of amendments
to Regulation No. 41”.
Point 20 was deleted in order to bring Annex 1 in line with the corresponding annex in
UN Regulation No. 41-04. The following points were renumbered accordingly.
A second Communication form was added with the header:
“Part B NORESS for vehicle types approved according to Regulations No. 9 or 63”.
Justification: The existing Annex 1 is exclusively related to NORESS for vehicles type
approved according to UN Regulation No. 41-04.
11.
Annex 3, paragraph 4
The reference in paragraph 4 to the appendix of Annex 3 was deleted and replaced by
references to the appropriate paragraphs in the corresponding vehicle UN Regulations
(Regulation No. 9, Regulation No. 63 and Regulation No. 41).
20
The appendix is dedicated to L3 category vehicles, but the requirements should also be
fulfilled for the other L category vehicles falling under the scope of this Regulation.
12.
Annex 4, Statement of Compliance with the Additional Sound Emission
Provisions
A new annex 4 was added for NORESS that have to fulfil the requirements of the new
paragraph 6.3.4 of this Regulation in order to align the ASEP requirements with UN
Regulation No. 41-04.
These amendments were adopted in the 64th meeting of GRB.
Amendments for future consideration
Further amendments proposed for UN Regulations Nos.9 and 63 were prepared as informal
documents and presented and discussed at the 64th GRB, but were taken on board for further
consideration in future meetings. These proposals are related to the following issues:
1. Amendments for UN Regulation No. 63, presented at 64th GRB in Geneva (5-7/9/2016)
and related to the inclusion of powered cycles as an additional subcategory, kept on the
agenda for further consideration at future meetings.
2. Points related to L-category vehicles proposed for future work of GRB.
The following items, proposed for future work in GRB, are based on the results of this study,
which concluded the amendments proposals for UN Regulations Nos. 9, 63 and 92,
submitted as official documents to the 64th GRB. They were submitted to GRB as informal
document and discussed at the 64th GRB; they were taken on board by the GRB for further
consideration at future meetings and in future informal meetings between the EC and
interested parties, merely IMMA and ACEM.
a. ASEP requirements in UN Regulation No. 9 for those vehicles whose power to
mass ratio exceeds 50 W/kg, in correspondence to UN Regulation No. 41-04.
b. Hybrid Electric Vehicles (HEVs) to be included in UN Regulations Nos. 9 and 4104.
With reference to the discussions between the EC and IMMA/ACEM on the current
amendment proposals for UN Regulations Nos. 9, 63 and 92, initially submitted to
the 63rd GRB by the EC expert as informal documents, it was agreed to incorporate
HEVs in the ECE R9, mentioning the engine capacity and not the power to mass
ratio, until ISO has finalised its current work on system power specifications for Lcategory HEVs.
This was accepted, but it should be ensured that the ISO work will be made
transparent and accepted by GRB. It was proposed as a future work subject the
implementation of HEVs in UN Regulation No. 41-04 and a corresponding
amendment of the requirements for HEVs in UN Regulation No. 9 as soon as ISO
has finalised its work.
c.
Revision of the measurement methods for L5 category vehicles.
For L5 vehicles designed for the carriage of passengers (also called tricycles and
trikes), the same measurement method as for L3 vehicles (UN Regulation No. 41-04)
should be applied and the same subcategories based on power to mass ratio should
be used.
21
Recommendations on items that remain to be addressed
In addition to the above amendments, a number of recommendations were made with regard to
items that remain to be addressed by the regulations:

Roadside stationary tests may only be partially effective, because silencers can be tuned
to perform well at stationary conditions but allow high sound levels when used in
acceleration mode. Although specifying a roadside or inspection and maintenance test
including vehicle acceleration is technically demanding, this is an area that could potentially
lead to large improvements.

Optimizing vehicle allocation to the UN Regulations may still be relevant. For example, L2e
vehicles are technically far more similar to L1e ones, hence their coverage by R63 instead
than R9 would be advisable. Similarly, moving L4 vehicles under the coverage of R41
makes sense, given the almost identical specifications of L3e and L4e (this being an L3e
vehicle with sidecar).

ASEP proposals for high powered L5e and L6e vehicles, not intended for the carriage of
goods, were made to GRB, but will require further study given that today these can only be
based on UN Regulation No. 41 ASEP.

The regulations may still be improved further to close remaining loopholes for a ‘defeat
device’ approach. For example, the strict control of entry speed for the pass-by test may
give ground for sound optimisation at acceleration from this speed only.

Reference to ISO standards are not publicly available free of charge. Hence, the relevant
ISO work should be made transparent in the context of GRB.
Cost-Benefit of proposed amendments
In order to justify the need for further action in terms of L-category sound control, a cost-benefit
analysis has been performed for the appraisal period 2016-2036. In this analysis, only mopeds (L1
category vehicles) and motorcycles (L3 category vehicles) were considered due to their by far
predominant numbers within the EU member states. Separate calculations were conducted for
Southern and Northern Europe, due to the difference in vehicle numbers and traffic flows of Lvehicles used in these regions.
The study included the effect of ‘illegal exhausts’ under the assumption that these exceed other
traffic noise levels by 10-15 dB for motorcycles and 7-10 dB for mopeds. The fraction of vehicles
equipped with exhausts of such noise level is assumed to be around 25%, although this value may
vary considerably in different countries and little reliable data on this is available. The modelling has
been done for representative road categories in the EU, assuming different traffic conditions for
each road type.
Benefits are estimated by the reduction of average noise levels at the dwelling façade. Annoyance
is generally associated with the annual average LDEN level at the dwelling façade (equivalent sound
pressure level weighted for day-evening-night), whereas sleep disturbance is associated with the
night level Lnight. Reducing traffic noise is considered an ‘amenity’ for which households are willing
to pay. It also produces health benefits, particularly reducing the occurrence of acute myocardial
infarction.
Additional costs for enhanced noise control are expected for vehicle manufacturers, the retail
sector, and road enforcement and market surveillance authorities. For the manufacturers of
vehicles and silencers costs include additional R&D, production costs and testing and certification
costs. For retailers, the cost originates from loss of sales of NORESS. Finally, additional costs for
enforcement and market surveillance authorities include costs for additional roadside testing minus
costs for potential fines collected.
22
Based on these considerations, the following scenarios were formulated:
 Scenario 1, baseline: No effect on excessive noise, no changes in enforcement or parts
sales, 25% of L-category vehicles are assumed to produce more noise due to illegal
exhausts.
 Scenario 2: Half of all excessively noisy L-category vehicles (12.5% of total fleet) are
assumed quieter by
a) 15 dB for motorcycles and 10 dB for mopeds,
b) 10 dB for motorcycles and 7 dB for mopeds,
both with better enforcement and less sales of illegal exhausts;
 Scenario 3: All excessively noisy L-category vehicles (25% of total fleet) are quieter by
a) 15 dB for motorcycles and 10 dB for mopeds,
b) 10 dB for motorcycles and 7 dB for mopeds,
both with better enforcement and less sales of illegal exhausts.
The results of the analysis for each scenario are shown in Table ES.2. In all cases but baseline
Scenario 1, a positive cost-benefit ratio is calculated, showing that there can be significant benefits
by reducing sound levels of L-category vehicles. For a noise reduction of 10 dB for motorcycles and
7 dB for mopeds producing excessive sound level, for half of the vehicles, the benefit-to-cost ratio
is 10, and for all the vehicles, 20. If the noise reduction is actually higher, 15 dB for motorcycles
and 10 dB for mopeds producing excessive sound level, the benefit to cost ratio is higher too, up to
47 in the best case.
For scenario 3b, the average reductions of equivalent noise levels for all affected roads are
estimated at 0.1 dB for Northern Europe and at 1.1 dB for Southern Europe. Due to the particular
characteristics of L-category vehicles sound emission, annoyance would be reduced and health
benefits increased significantly.
23
Table ES.2: Results of the CBA per scenario.
24
1
Introduction
1.1 General
The sound emitted from road transport, and in particular the excessive levels emitted by some Lcategory vehicles, may be perceived as noise and, thus, be disturbing or problematic. The “L”
vehicles category consists of a rather wide and diverse range of vehicles, ranging from small electric
bikes, to much larger three-wheelers and quadricycles used for the transport of people or the
transfer of goods. The engines utilized also range from low-speed diesel engines used in microcars, to high specific-power high-speed petrol ones used in applications like sports or super-sports
motorcycles.
Noise emission from road vehicles, and especially the L-category ones, is a major nuisance for
many European cities and it is considered to degrade the quality of life. Moreover, it is scientifically
proven that excessive noise levels may be harmful for health, especially in the urban areas, and
are of equal environmental and health consequences as normal gaseous pollutants produced by
road vehicles (Kim et al., 2012). Several studies (e.g. Pavioti & Vogiatzis, 2012 and Vougias &
Natsinas, 1986) have in particularly shown that several L-vehicles with their high dynamic range,
high engine speed, and enthusiastic drivers, are a significant source of annoyance and sleep
disturbance.
The problem is magnified by the fact that original noise control equipment (silencers) is removed
and replaced either with type-approved silencers (as replacement parts) or, often, with custom
made silencers. This trend is based on the perception by the powered two wheeler owner of loud
sound being a head-turner for the rider (Lai and Aritejo, 2013) and/or that a so-called ‘open’ exhaust
increases vehicle power. Common evidence suggests that silencers are the largest aftermarket
sector for powered two wheelers.
In order to address the issues mentioned above, the sound levels of L-category vehicles are
regulated so as to reduce noise pollution, especially in cities and quiet rural areas. The type
approval process includes certification that the vehicle sound level is below permissible limits.
Legislating on approval requirements of vehicles with respect to sound emissions affects industry,
national authorities, and social partners. Cost effective type-approval and conformity of production
requirements, which are to be fulfilled by a new vehicle type before a manufacturer may place it on
the EU market, are of paramount importance.
The sound level limits for vehicle approval also constitute reference values for the market
surveillance, monitoring and legislation enforcement national and local authorities, for an effective
regulation of the on-road vehicle fleet performance. This actually refers to the effectiveness of
market surveillance, i.e. making sure that vehicles placed on the market, and subsequently on the
road, comply with the maximum sound limits and requirements. Secondly, and most importantly, it
ensures that vehicles continue throughout their lifetime to comply with enforced sound limits, with
potential deviations owed either to malfunctions of OEM silencers or, more often, use of
inappropriate replacement parts. Random (roadside) and scheduled (roadworthiness) vehicle tests
are therefore potentially capable of identifying deviations, as long as transparent and detailed
information is in place for monitoring authorities to check the vehicle compliance.
Effectively maintaining approved sound levels at fleet level is therefore based on several
complementary factors, ranging from noise type approval test quality, OEM and aftermarket
surveillance, tampering control stringency, roadside vehicle monitoring systems in place, etc. With
the new sound level limits for Euro 5, the European Commission seeks to provide an improved
sound level range in order to deliver noise reduction of real-world traffic at fleet level.
25
1.2 Current state of play
Currently, Regulation (EU) No 168/2013 regulates in Annex VI (D) the limits of the sound level
emitted by the different L-category vehicles up to the Euro 4 sound limit. According to article 23 of
this regulation, a study will be performed to set the sound level limits for the Euro 5 step and adopt
these limits with the ordinary legislative procedure as set out in article 74 (iv).
So far, sound regulations were based on tests specified in Directive 97/24/EC for all vehicles in Lcategory, with a key distinction between mopeds and motorcycles. This Directive defined two test
procedures, a pass-by test with the vehicle driven on the road at a given speed, differentiated for
mopeds (30 km/h) and motorcycles and tricycles (50 km/h), and a test with the vehicle stationary in
a test environment and the engine running freely at a given speed setting, depending on the rated
speed of the engine. The tests are conducted with ambient microphones located at a specified
distance from the vehicle, intended to register noise levels under representative operating
conditions. The pass-by test assesses all noise sources, including engine, exhaust, transmission,
aerodynamic and road-tyre interaction, whilst the stationary test is specific to the engine and
exhaust operation. Provisions for conformity of production are also included both for OEM and for
replacement silencers. Also, a conditioning procedure for silencers before testing is proposed.
Finally, this Directive provides provisions regarding anti-tampering measures, including silencers.
New levels and methods for the control of noise are included in Regulation 168/2013 and
Commission Delegated Regulation No 134/2014, respectively, which came into force from Jan. 1,
2016. The permissible sound levels are now better specified for the different L-vehicle types.
However, the technical details of the testing have been basically transferred from the Directive
97/24/EC. On the other hand, the new pieces of regulation include improved provisions regarding
market surveillance and anti-tampering. Hence, as a package, the new Regulation offers enhanced
control of real-world fleet level emissions.
Most importantly, for motorcycles (L3e) the UN Regulation No 41 was recently acceded by the EU
regulation, as was already prepared for in the EU Regulations, so that the Euro 4 motorcycles will
have to comply with the improved specifications of the R41 Regulation. The new Regulation (R4104) includes more strict conditions for testing, a full throttle acceleration test, two gear tests when
this is deemed necessary, and lower sound limits for the actual test. Furthermore “Additional sound
emission provisions” (ASEP) were added to the sound emission requirements. These provisions
shall ensure that the sound emission of the vehicle in real world driving conditions that are not
covered by the type approval test, is in line with the sound emission of the type approval test.
Therefore, the new test is expected to more thoroughly address individual vehicle sound control
under a wider range of real-world operating conditions.
Additional UNECE regulations address noise control for more vehicle types, including threewheeled mopeds, tricycles and quadricycles (Regulation 9), two-wheeled mopeds (Regulation 63)
and replacement silencers (Regulation 92). These Regulations are currently being considered to
be acceded by the EU regulatory context. Before this step, due diligence of the relevant UN
regulations is required.
26
1.3 Study approach
The current study aimed at performing a due diligence of the three UNECE regulations regarding
noise control of non-L3e vehicles, specifically R9, R63, and R92. Due diligence in that sense means
checking the applicability of these regulations within the EU context, and the coverage they offer in
terms of the noise control issues that EU has identified as priorities, including market surveillance
and information to enforcement authorities.
To achieve this, the study team first attempted to understand the current issues regarding noise
from L-vehicles, in particular the ones falling within the scope of the three regulations. The public
perception of the nuisance caused by L-vehicles in cities forms the basis for moving towards a more
stringent noise control framework. The view of stakeholders is necessary to evaluate the need for
change of the regulatory framework. These stakeholders include technical services, type approval,
monitoring and enforcement authorities, cities and other regional authorities affected by road traffic
noise. Their opinion is surveyed on completeness and the information provided by the new
regulations compared to the existing regulatory framework.
Based on information collected from the different sources, an assessment was made of the benefits
of real-world traffic noise reduction from more strict sound control of L-vehicles and of the costs of
the enhanced control technology. This resulted in the cost-benefit analysis of the new regulatory
approach.
Finally, based on this research, the team drafted amendments to the UN Regulations for
consideration, before these regulations are acceded in the EU regulatory framework.
1.4 Structure of the report
Further to this introductory chapter, this report consists of the following chapters:
Chapter 2: Presentation and results of the stakeholder survey
Chapter 3: Amendments and justification of the relevant UNECE Regulations
Chapter 4: Presentation of the approach and results of the cost-benefit analysis
A number of Annexes presenting details of the work performed within the project.
27
2
Stakeholder survey
The first main objective of the project was the systematic collection and evaluation of the responses
from several stakeholder groups. In addition, the objective was the processing and analysis of the
received feedback, so that useful conclusions could be drawn and suggestions be made. This
means that the evaluation of responses does not only involve the production of arithmetic averages
of the answers, but also assesses, based on the level of completeness and the quality of the
response received, how serious the various issues are and which are the ones which seem to be
the most significant.
The main outcomes of this activity, which are further described in more detail in the subsequent
sections, are summarized as follows:
 A questionnaire (with two distinct types) that has been used as the main tool for collection of
feedback from stakeholders’ groups (see ‘Annex I: Questionnaire that has been used’).
 Filled in questionnaires received (see ‘Annex II: Filled in questionnaires received’).
 Processing of questionnaires and analysis of responses (see ‘Annex III: Collection and
processing of responses’).
 Assessment and conclusions drawn for the various issues concerned.
Legislating, monitoring and controlling of excessive noise emissions involve many different players
in the field such as technical services and type approval authorities, market surveillance and
enforcement authorities, social partners, industry, etc. Hence, strict and comprehensive control of
L-category vehicles sound levels does not only refer to a thorough testing and type-approval
procedure, but also to the tools and information delivered to the monitoring and enforcement local
authorities for an effective regulation of the in-use performance. This relates to the effectiveness of
market surveillance, i.e. making sure that vehicles placed on the market (and subsequently on the
road) comply with sound limits and, most importantly, ensuring that vehicles continue to comply
with these sound limits throughout their lifetime.
Potential deviations may be owed either to malfunctions of OEM silencers or, more often, use of
inappropriate replacement parts; random (roadside) and scheduled (roadworthiness) tests are
possibly capable of identifying deviations, as long as transparent and detailed information is in place
for monitoring authorities to check the vehicle compliance. Social partners and stakeholders such
as concerned cities, citizens, noise abatement societies and other environmental organizations,
etc. are usually focussed on noise issues and ask for more action on noise control.
A public consultation of the players and stakeholders mentioned above would improve
understanding of current issues regarding noise from L-category vehicles (communication
component of the project). For example, the perception of people on how much these vehicles
continue to be a nuisance in cities (and other areas) will formulate the basis for moving into a more
stringent noise control framework. Also, the view of technical services, type approval, monitoring
and enforcement authorities on the completeness and the information provided by the new
regulations, compared to the existing regulatory framework, is necessary to evaluate the need for
change.
In this consultation procedure the frequently contradicting interests of stakeholder groups need to
be taken into account in a balanced and productive manner. A win-win situation is desirable, i.e. for
example enhanced enforcement and anti-tampering considerations are for the benefit of the citizens
(lower noise), the drivers (higher safety), large companies (in-use conformity and durability) and
SMEs (use of only type-approved replacement components). As a means to achieve better in use
compliance, the regulatory text should provide sufficient information and tools to the enforcement
authorities to check the quality of the noise control system. This is a very effective measure and to
the benefit of all stakeholders.
28
2.1 Organization of the public consultation procedure
2.1.1 The questionnaire
Table 1 summarizes the two types of the questionnaire that have been used to gather feedback.
Table 1: Summary of the two versions of the questionnaire
Questionnaire A
Target
group
 Countries, cities, citizens
 Motorcycle and noise concerned
associations
 Environmental organizations and
institutes
Focus on
 Environmental and social aspects of
noise pollution from L-category
vehicles
 Effects of noise, impacts on citizens’
well-being
Structure
 Section 1: Environmental and social
aspects of noise pollution from Lcategory vehicles (12 questions)
 Section 2: Technical issues related to
noise control regulations (3 questions)
Questionnaire B
 Technical services and type approval
authorities
 Departments of transport, market
surveillance & enforcement authorities
 Industry and manufacturers
 Technical issues related to noise control
regulations
 Effectiveness of TA procedure, market
surveillance and enforcement
 Section 1: Technical issues related to
noise control regulations (6 questions)
 Section 2: Market surveillance and
enforcement (7 questions)
 Section 3: Market surveillance and
enforcement (4 questions)
 Section 3: Environmental and social
aspects of noise pollution from L-category
vehicles (6 questions)
 Other: Comments, references, contact
info (3 questions)
 Other: Comments, references, contact
info (3 questions)
Questionnaire A is intended for social partners (cities, citizens, environmental and noise concerned
associations, etc.) and mostly focuses on the environmental and social aspects of noise pollution
from L-category vehicles (12 out of 22 questions in total are about effects of noise and impacts on
citizens’ well-being).
Questionnaire B is intended for authorities (type approval, market surveillance and enforcement,
etc.) and industrial stakeholders and mostly focuses on the technical issues related to noise control
regulations and on the effectiveness of current noise control procedures (13 out of 22 questions in
total are about the TA, market surveillance and enforcement).
Different wording has been used for some of the questions common to both versions, depending
on the target group. The two versions of the questionnaire are available at ‘Annex I: Questionnaire
that has been used’.
At the beginning of each version (before the questions part) some background information on the
project and on the objectives of the questionnaire itself is given, as well as short guidelines for filling
it in. The questions are then grouped in sections (e.g. environmental and social aspects, technical
issues related to regulations, market surveillance and enforcement).
29
2.1.2 Contacted stakeholders, authorities, associations, etc.
In total, the questionnaire has been sent to 123 individual entities, in a balanced manner, organized
as follows:
 Social partners
o Countries (i.e. ministries of foreign affairs, national permanent representations to the
EU), cities (i.e. local authorities, municipalities, European cities networks), citizens (i.e.
European consumer and other organizations)
o Motorcycle (i.e. drivers) and noise concerned associations
o Environmental organizations and institutes
 National authorities
o Technical services and type approval authorities
o Departments of transport, market surveillance and enforcement authorities
 Industrial stakeholders
These entities (organizations, associations, institutes, manufacturers, authorities, departments of
transport, etc.) have been contacted primarily by e-mail, followed up with 1 or 2 reminder e-mails.
Some targeted phone calls have also been made to stakeholders from whom a reply was desirable.
A web (skype) meeting has also been organized on 9 Oct. 2015 with ACEM, IMMA, Honda, and
Piaggio.
The complete list of contacted stakeholders is provided in Table 2.
30
Table 2: List of entities1 that the questionnaire has been sent to.
Countries, cities, citizens
CEMR - Council of European Municipalities and Regions
POLIS - European Cities and Regions Networking for Innovative Transport Solutions
Transport Research Centre Brno (CZ)
City of Utrecht (NL)
Madrid Acoustic Center (ES)
Tallinn Transport Department (EE)
BKK - Centre for Budapest Transport (HU)
EUROCITIES - Network of major European cities
Ajuntament de Barcelona / Gerència d’Ecologia, Urbanisme i Mobilitat / Direcció d’Energia i Qualitat Ambiental / Dept.de Reducció de
la Contaminació Acústica (ES)
City of Rotterdam (DCMR/EPA Rijnmond region)
The Hague (NL)
Hamburg (DE) Ministry of Environment and Energy - Directorate-General for Emission Protection and Industrial Plants - Department
for Noise Abatement
MAIRIE DE PARIS / DEVE / AEU / Pôle Bruit (FR)
BEUC - The European Consumer Organisation
ANEC - The European Consumer Voice in Standardisation
CEA - The European Insurance and Reinsurance Federation
FEVR - European Federation of Road Traffic Victims
BG: Mission of Bulgaria - Permanent Representation Of Republic Of Bulgaria To The EU
CZ: Ministry of Foreign Affairs of the Czech Republic
DK: Ministry of Foreign Affairs of Denmark
EE: Ministry of Foreign Affairs - Ministry of Economic Affairs and Communications
FI: Ministry for Foreign Affairs of Finland
FYROM: Mission of FYROM
GR: Permanent Representation of Greece to the European Union
HR: Mission of Croatia - Permanent Representation of the Republic of Croatia to the EU
IE: Permanent Representation of Ireland to the European Union
IS: Mission of Iceland - Embassy of Iceland in Brussels
LI: Mission of Liechtenstein - Embassy of Liechtenstein in Brussels
LT: Ministry for Foreign Affairs - Permanent Representation of Lithuania to the European Union
ME: Mission of Montenegro
MT: Permanent Representation of Malta to the EU (Malta EPA - Environment and Planning Authority)
NO: Mission of Norway - The Norwegian Mission to the EU
PT: Portuguese Permanent Representation to the European Union
RO: Permanent Representation of Romania to the EU
RS: Mission of Serbia
SE: Permanent Representation of Sweden to the EU
SI: Permanent Representation of Slovenia to the EU
TR: Mission of Turkey
Motorcycle and noise concerned associations
FEMA - The Federation of European Motorcyclists' Associations
IMA - International Motorcycle Alliance
FIM - Fédération Internationale de Motocyclisme
FIA - Federation Internationale de l' Automobile (member of AFCAR)
UK Noise Association
Norwegian Association against Noise
Noise Abatement Society
NSG (NL) - Nederlandse Stichting Geluidshinder
Stichting Innonoise (NL)
UKISC - United Kingdom and Ireland Soundscape Community
EHIMA - European Hearing Instrument Manufacturers Association
Environmental organizations and institutes
1
The list in Table 2 also contains entities that have not directly been contacted by LAT/AUTH, but to whom the
questionnaire has been forwarded by EC DG GROW or other entities (e.g. POLIS, EUROCITIES, ETSC, and
UNECE Working Party on Noise (GRB) forwarded the questionnaire to further groups of people).
31
EEA - European Environment Agency
EEB - European Environmental Bureau
ETSC - European Transport Safety Council
UBA (DE) - Federal Environment Agency
T&E - Transport & Environment
ICCT - International Council on Clean Transportation
IFEU - Institute for Energy and Environmental Research Heidelberg GmbH
RIVM (NL) - National Institute for Public Health and the Environment
AVERE - European Association for Battery, Hybrid and Fuel Cell Electric Vehicles
VDE - Association for Electrical, Electronic & Information Technologies
VUB - Vrije Universiteit Brussel
KU Leuven - Katholieke Universiteit Leuven
UniFI - Universita degli Studi de Firenze
INTA (ES) - National Institute for Aerospace Technology
ECORYS - European Research and Consultancy Company
IANGV - International Association for Natural Gas Vehicles
Technical services and type approval authorities
TÜV NORD
VCA - The UK Vehicle Type Approval authority
ARAI - Automotive Research Association of India
AT: Ministry for Transport, Innovation and Technology
BE: Service Publique de Wallonie (SPW) - Direction générale opérationnelle de la Mobilité des voies hydrauliques
Direction Certification et Homologation
BG: Executive Agengy Road Transport Administration
BG: Technical Control Inspectorate (KTI)
CZ: Ministry of Transport
DK: Danish Transport Authority
FI: Finnish Transport Safety Agency
FR: UTAC CERAM
IT: MIT - Ministero delle Infrastrutture e dei Trasporti
LT: State Road Transport Inspectorate under the Ministry of Transport and Communications
RO: Romanian Automotive Register
SE: Road Traffic Department
DE: FAKT-GmbH Kraftfahrtechnisches Prüf- und Ingenieurzentrum
DE: SGS-TÜV SAAR GMBH
UNECE Working Party on Noise (GRB)
CH: Swiss Federal Department of the Environment, Transport, Energy and Communications DETEC - Federal Roads Office - Road
Traffic Division - Vehicles
CN: CNMTC - China National Motorcycle Testing Center
CN: SMVIC - Shanghai Motor Vehicle Inspection Center (secretariat of Motorcycle Branch of Chinese National Technical Committee
of Auto Standardization)
ES: Applus + IDIADA (Design, engineering, testing and homologation services to the automotive industry)
ES: LCOE Barcelona (Laboratorio Central Oficial de Electrotecnia - Vehicles Approval)
FR: Ministère de l'écologie, du développement durable et de l'énergie
HU: TÜV Rheinland InterCert Kft.
HU: KTI - Institute for Transport Sciences
TR: Türk Standartlari Enstitüsü (TSE)
Departments of transport, market surveillance and enforcement authorities
AT: Federal Ministry of Science, Research and Economy - Division I/5
BE: Federal Public Service Mobility and Transport
CH: FOEN (Federal Office for the Environment - Topic Noise)
CY: Ministry of Transport, Communications and Works (Department of Road Transport & Department of Public Works)
ES: MINETUR - Ministerio de Industria, Energía y Turismo, Subdirección General de Calidad y Seguridad Industrial
GR: Ministry of Infrastructure, Transport and Networks
GR: Traffic Police Departments in Thessaloniki
IE: Road Safety Authority
LU: SNCH - Société Nationale de Certification et d'Homologation
LV: CSDD - Road Traffic Safety Directorate
MT: Malta Competition and Consumer Affairs Authority
NO: Norwegian Public Roads Administration
32
PL: TDT - Transportation Technical Supervision
PL: ITS - Motor Transport Institute
PT: IMT - Mobility and Transport Institute, I.P.
SE: Swedish Transport Administration
SK: Ministry of Transport, Construction and Regional Development
TR: Ministry of Science, Industry and Technology
TISPOL - European Traffic Police Network (Federale Wegpolitie Belgium)
DE: Federal Ministry of Transport, Building and Urban Development
FI: Ministry of Transport and Communications
NL: RDW
RU: MINISTRY OF TRANSPORT OF THE RUSSIAN FEDERATION
UK: Department for Transport
Industry and manufacturers
ACEM - The Motorcycle Industry in Europe
ATVEA - All Terrain Vehicle Industry European Association
EQUAL - European Quadricycle League
IMMA - International Motorcycle Manufacturers Association
JAMA Europe - Japan Automobile Manufacturers Association
SIAM - Society of Indian Automobile Manufacturers
CAAM - China Association of Automobile Manufacturers
AECC - Association of Catalyst Manufacturers
CLEPA - The European Association of Automotive Suppliers
CECRA - European Council for Motor Trades and Repairs (member of AFCAR)
FIGIEFA - Automotive Aftermarket Distributors (member of AFCAR)
MATTHIES - Johannes J. Matthies GmbH & Co. KG & AFCAR
ETRTO - The European Tyre and Rim Technical Organisation
BOSCH (DE)
MECA - Manufacturers of Emission Controls Association
Yamaha Motor Europe, branche Nederland
Kawasaki Motors Europe
KHI - Kawasaki Heavy Industries
Renault (FR)
CONEBI – Confederation of the European Bicycle Industries
RAI Vereniging (NL) - Rijwiel & Automobiel Industrie
Accell Group (NL)
Akrapovič (SI)
Arrow (IT)
LeoVince (IT)
Yoshimura (JP)
The graph in Figure 1 summarizes the stakeholders’ groups that the questionnaire has been sent
to, by showing the number (and corresponding percentage) of individual entities that have been
contacted (organized into groups as discussed above).
33
Figure 1: Individual entities that the questionnaire has been sent to (organized into groups)
2.1.3 Collection of responses
In total, there were 66 replies to our request for answering the questionnaire, which is ~54% of the
number of entities contacted. These are analysed as follows:
 44 positive replies (filled in questionnaires received), which is ~36% of the number of
entities contacted.
 12 negative replies.
 4 entities forwarded the questionnaire to further groups of people (POLIS, EUROCITIES,
ETSC, and UNECE Working Party on Noise (GRB)).
 6 entities promised to answer, but never did.
Since POLIS and EUROCITIES are considered as important social partners and GRB
feedback/interest is important to know, a summary of the replies received through these entities
(which forwarded the questionnaire to further groups of people) is provided below2:
 Through POLIS, there were 4 positive replies (Budapest, Madrid, Tallinn, and Utrecht) and 1
negative reply (Brno).
 Through EUROCITIES, there were 5 positive replies (Barcelona, Hague, Hamburg, Paris,
and Rotterdam).
 Through GRB, there were 10 positive replies (AT, CH (2), CN (2), ES (2), FR, NL, and NO).
In Figure 2 there is a split of the positive replies (filled in questionnaires), organized as in section
2.1.2. According to this, there are 22 responses received from social partners, 17 from authorities
(EU member states and other countries), and 5 from industrial stakeholders. By adding responses
from authorities and industry to an extended ‘technical’ entities group, it can be seen that there is
an exactly equal split of responses received from social partners (22) and ‘technical’ entities (22).
2
It is clarified that the replies (positive/negative) received through these entities have already been taken into account
in the above analysis; that is, they have already been summed up to the total 44 positive and 12 negative replies.
34
This is a very good indicator of their representativeness and of the quality of the final outcomes of
this public consultation procedure.
Figure 2: Filled in questionnaires received (44) organized into groups
In general, the questionnaire has been filled in by a wide range of stakeholders in different and nonoverlapping fields, i.e. national responses (from technical services, type approval authorities,
transport departments, market surveillance and enforcement authorities), industry and
manufacturers, cities and regions, and various organizations (environmental, noise concerned,
motorcycle, consumer, etc.).
The 44 entities that have filled in the questionnaire are summarized below:
 National responses (TSs, TAAs, transport depts., market surveillance, enforcement):
o AT, BE, CH (2), DE, ES (2), FR, GR, IE, LV, MT, NL, NO, PL
o Outside Europe: CN (2)
 Industry & manufacturers:
o ACEM, ATVEA, CECRA, FIGIEFA, Akrapovič (SI)
 Cities & organizations (environmental, noise concerned, motorcycle, consumer,
other):
o Barcelona, Budapest, Hague, Hamburg, Madrid, Paris, Rotterdam, Tallinn, Utrecht
o CEMR, ANEC, FEVR, LI Embassy, Malta EPA, FEMA, Norwegian Association against
Noise, EEA, ICCT, RIVM (NL), AVERE, KU Leuven, UniFi
All 44 filled in questionnaires are available at ‘Annex II: Filled in questionnaires received’. The whole
public consultation process (contacted stakeholders, collection of responses, etc.) is summarized
in an excel worksheet (see ‘Annex III: Collection and processing of responses’, worksheet
“Stakeholders”). The information that can be found in it is summarized as follows:
 Stakeholders organized into groups (name, web site, contact person, e-mail, etc.).
 Date of contact, date of answer, filled in questionnaire received or not.
 A short comment (e.g. why a negative response was given, if the provided answers were
detailed enough, what was the outcome of a phone call, etc.).
35
 Some statistical info (number of ‘entities’ contacted, number of all responses, number of
questionnaires received per group of stakeholders, etc.).
An indicative screenshot of this public consultation process summary is given in Figure 3.
Figure 3: Summary of the public consultation procedure (indicative screenshot).
2.2 Processing of questionnaires and analysis of
responses
2.2.1 General approach and organization
All answers have been transferred initially to a single excel worksheet in an organized manner, one
below the other (see ‘Annex III: Collection and processing of responses’, worksheet “Answers”).
Two separate templates have been used for the two different types of the questionnaire (A, B); as
a result, all answers are gathered together in this worksheet. Figure 4 shows an indicative
screenshot of a filled in questionnaire transferred in excel for further processing.
Figure 4: Screenshot of a filled in questionnaire transferred in Excel.
This approach for organization has the advantage that, by applying a data filter, one can select a
specific question and have an overview of all answers to it. For example, in Figure 5 there is an
36
example of data filtering, which provides all answers to question Q1 of questionnaire A, “Do you
consider noise from L-category vehicles to still be a significant problem?” This filtering of questions
assists in the further processing of the answers received, e.g. calculation of the percentages of
each response to a specific question and creation of pie charts, extraction of main findings and
conclusions, suggestions for improvement, etc.
Figure 5: Example of data filtering (here, answers to Q1 in questionnaire A).
2.2.2 Analysis of responses and main findings
By applying data filtering to all questions and by analysing the responses received, the main findings
(described below in this section) can be concluded. These are also available at ‘Annex III: Collection
and processing of responses’, worksheets “A_Q1” to “A_Q22_B_Q22”.
It is noted that if a question is common in both questionnaires, the analysis about it is made together
for both questionnaire types A and B (e.g. worksheet “A_Q11_B_Q18”, “Would you like to see more
strict regulation in controlling noise from L-cat vehicles?”), but the pie charts and discussion are
usually provided separately for ‘social’ and ‘technical’ entities in order to see how different groups
of stakeholders give different answers to the same question depending on their interests.
Furthermore, it is also clarified that pie charts are provided only for questions for which an indicative
list of pre-defined answers was given in the questionnaire (e.g. Yes/No/Partially, etc.). For the
remaining questions (e.g. those asking for suggestions), the (text) replies were very much
dispersed; hence, a pie chart was not considered appropriate for them. Of course, the latter are
summarized (together with all replies) in chapter 2.3, where the main conclusions and main findings
from all responses are provided.
37
Environmental and social aspects of noise pollution from L-category
vehicles
A_Q1, “Do you consider noise from L-category vehicles to still be a significant problem?”
A_Q2, “Which areas do you consider that are mostly affected?”
A_Q1 replies summary: Noise from L-category vehicles is considered to still be a significant problem
A_Q2 replies summary:
 mostly in urban areas,
o secondarily, in rural areas.
(Figure 6)
Figure 6: Answers to Q1 and Q2 of questionnaire A.
38
A_Q3, “During which period of year do you consider that the problem is more intense?”
A_Q4, “In a typical urban neighbourhood, noisy L-cat vehicles are:”
A_Q3 replies summary: The problem is considered more intense
 during all periods of the year,
o secondarily, during weekends.
A_Q4 replies summary: Noisy L-category vehicles are characterized as ‘disturbing’ or ‘rather
disturbing’ by almost all participants of the survey.
(Figure 7)
Figure 7: Answers to Q3 and Q4 of questionnaire A.
39
A_Q5, “As a pedestrian or cyclist, I am threatened by L-cat vehicles because their noise distracts
my attention.”
A_Q5 replies summary: 50% of the participants characterize noisy L-category vehicles as a threat
because their noise distracts their attention when walking or cycling.
(Figure 8)
Figure 8: Answers to Q5 of questionnaire A.
40
A_Q6_B_Q14, “If you believe that noise from L-cat vehicles is a problem, can you rate from 1 (main
responsible) to 4 (less responsible) who is responsible for this?”
A_Q6_B_Q14 replies summary: Main responsible for noise is
1. the drivers that illegally tune their vehicles,
2.
3.
4.
the weak enforcement of regulations,
the non effective regulations,
the industry.
Authorities and industrial stakeholders give 65% to the drivers (compared to 48% of the social
partners).
Weak enforcement of regulations is considered the second main responsible with approximately
same percentage in both cases.
(Figure 9)
Figure 9: Answers to Q6 of questionnaire A and Q14 of questionnaire B.
41
Indicative answers to A_Q6_B_Q14
Madrid Acoustic Center (ES)
The drivers are not sensitized with the noise control and tune their vehicles easily because the
"non-original exhaust or silencing system" industry designs devices easily alterable, with several
removable inserts to attenuate noise.
The stationary test is insufficient for the inspection of motorcycles in use.
ANEC - The European Consumer Voice in Standardisation
Young irresponsible people take pleasure in roaring round the countryside making as much noise
as possible. Better legislation & enforcement are the second responsible as the drivers can
legally buy and install aftermarket exhaust systems, which make more noise.
The original silencer which comes with the motorbike, as well as the replacement silencer
(including non-original aftermarket products), should meet requirements of regulation (approval).
FEMA - Federation of European Motorcyclists' Associations
Industry provides the vehicles with sound exhaust systems that are quite well as long as the users
stay away from it. It is a (small) group of users that modify the exhaust system with aftermarket
gear that is not according to the regulation or make alterations to the system themselves.
Enforcement is in most countries virtually non-existent. Making more or stricter regulations is
useless without proper enforcement of the current regulations first.
EEA - European Environment Agency
The problem arises from vehicles that are plainly too loud or disturbing in the character of the
noise. The blame for this will always lie with the standards by which they should be regulated, but
also arises due to lack of enforcement of any regulation.
Applus + IDIADA (ES)
A stronger enforcement would lead to minimize the illegally tuned vehicles and would result in
more fair competition between manufacturers.
DE: Ministry of Transport and Digital Infrastructure
Because regulations are not effective, industry can build their solutions “around requirements” and
drivers can tune their silencers or use special-silencers on their vehicles.
Enforcement via sound measurements on e.g. road-side-checks is needed because vehicles are
not 100% safe in respect to noise (anti-tampering requirements).
42
A_Q7_B_Q15, “Most of the noise comes from”
A_Q7_B_Q15 replies summary: Most of the noise comes from
1. tampered vehicles,
2.
3.
motorcycles,
mopeds and other L-category vehicles.
The percentage of tampered vehicles (42%) could possibly be higher (6 questionnaires did not
include it as an option, due to an earlier version that was used).
The percentage of mopeds and other L-cat vehicles is not negligible (25%).
(Figure 10)
Figure 10: Answers to Q7 of questionnaire A and Q15 of questionnaire B.
43
A_Q8, “If you are a rider/driver of an L-cat vehicle, how would you rate the noise of your vehicle?”
A_Q9, “If you have been a motorcycle owner, have you ever replaced your vehicle’s silencer?”
A_Q10, “If you answered “Yes” in Q9, what was the prime reason for replacing your silencer?”
What do riders/drivers think?
A_Q8 replies summary:
 57% of the riders/drivers want their vehicle to be more silent.
A_Q9_A_Q10 replies summary:
 14% have replaced the silencer (however, the sample to this specific question is very small,
only 7 answers; actually, only 1 has replaced the silencer and the reason was more power).
(Figure 11)
Figure 11: Answers to Q8 and Q9 of questionnaire A.
44
B_Q16, “According to your experience, what is the percentage of motorcycle owners that replace
their vehicle silencer?”
B_Q17, “What do you think is the prime reason for a motorcycle owner to replace his/her vehicle
silencer?”
What do authorities and industrial stakeholders think?
B_Q16 replies summary:
 … that the percentage of motorcycle owners that replace the silencer is ~23% (rough
approximation),
B_Q17 replies summary:
 … that the prime reason for replacing the silencer is
1. improved noise (different sound than before, not specifying if it concerns more
or less dB),
2.
3.
4.
better looks,
more power,
other (more noise, less weight/cost, unavailability of original silencer e.g. after an accident).
(Figure 12)
Figure 12: Answers to Q16 and Q17 of questionnaire B.
45
A_Q11_B_Q18, “Would you like to see more strict regulation in controlling noise from L-cat
vehicles?”
A_Q11_B_Q18 replies summary: 90% of social partners and 70% of authorities and industrial
stakeholders want to see more strict regulation in noise control, on the following fields (e.g. sound
limits, anti-tampering, etc.):
 Prohibition of defeat devices and of easy manipulation by design, make more difficult to
remove parts from an approved silencer, ASEP, improve noise tests in more real driving road
conditions.
 Stricter sound limits, anti-tampering, more market surveillance, measures to make
enforcement of regulation easier, strict noise measurements by police control.
(Figure 13)
Figure 13: Answers to Q11 of questionnaire A and Q18 of questionnaire B.
46
Indicative answers to A_Q11_B_Q18
YES: DE Ministry of Transport and Digital Infrastructure
_ Because sound limits are low, many drivers want to change sound by using replacement silencers
(E-/e-marked but louder than original; grey zone but not acceptable), racing-silencers/not-forhighway-use-silencers (illegal) or modify the original- or replacement-silencer in the direction “more
sound” (illegal but often find).
_ Requirements should make sure that vehicle- and silencer-manufacturers find no loopholes (e.g.
variable geometries, test-cycle-beating) to deliver the sound driver wants to have.
_ On the other side, requirements should make road-side-checks of police and PTI-checks easy
and deliver safe-results (measurements or identification; information that replacement-silencer fits to
the motorbike; easy finding of modification or manipulation etc.)
No: ATVEA - All Terrain Vehicle Industry European Association
_ Lowering current sound level limits (which are already extremely stringent) will have no effect
unless they are properly enforced on the field.
_ Identically, anti-tampering is not the remedy as one will always find a solution to circumvent it.
_ Moreover, regulation must strike a balance between RMI provisions, which enlarge the number of
third parties having access to key technical information, and anti-tampering provisions.
47
A_Q12, “For a motorcycle costing 5,000 Euros, would you spend 100 Euros more when purchasing
it for better control of its noise?”
B_Q19, “According to your experience, do you believe that the candidate buyer of a motorcycle
costing 5,000 Euros, would spend 100 Euros more when purchasing it for better control of its
noise?”
A_Q12 replies summary: 85% of social partners say that they would pay more money for better noise
control of their L-cat vehicle (with some concerns that this would not lead to loss of power).
B_Q19 replies summary: Authorities and industrial stakeholders say that the percentage of
candidate buyers that would spend more money for better noise control is only 25%.
(Figure 14)
Figure 14: Answers to Q12 of questionnaire A and Q19 of questionnaire B.
48
Technical issues related to noise control regulations
A_Q13, “Are you familiar with the type approval (TA) procedure for noise control of L-cat vehicles?”
A_Q13 replies summary: Most of the social partners (57%) are not familiar with the type approval
procedure for noise control of L-cat vehicles.
(Figure 15)
Figure 15: Answers to Q13 of questionnaire A.
49
B_Q1, “How would you rate the overall TA procedure for noise control of L-cat vehicles?”
B_Q1 replies summary: The majority of authorities and industrial stakeholders characterize the
overall TA procedure for noise control as ‘easy to follow’.
(Figure 16)
Figure 16: Answers to Q1 of questionnaire B.
Indicative answers to B_Q1 (from stakeholders who suggest that TA ‘needs improvement’)
DE Ministry of Transport and Digital Infrastructure
_ Need for improvement at UN-R9: Quads/Tricycles have to bear an anti-tampering label at the
frame.
_ Need for improvement at UN-R63: Approach speed of L1-vehicles should be always maximum
speed.
_ Need for improvement at UN-R92: Manufacturer information about the “using area” of the RESS
is needed (via internet site of RESS-manufacturer or via UN-database: vehicle manufacturer,
vehicle type; trade name, engine capacity, engine power and model years; remarks). This
information is needed for PTI and road-side-checks of e.g. police.
CNMTC - China National Motorcycle Testing Center
Noise tests should be combined with the engine power.
50
B_Q2, “Do you encounter specific technical complications during the TA procedure for any of the
L-cat vehicle types?”
B_Q2 replies summary: The majority of authorities and industrial stakeholders do not encounter
specific technical complications during the TA procedure for any of the L-cat vehicle types.
(Figure 17)
Figure 17: Answers to Q2 of questionnaire B.
Indicative answers to B_Q2
Partially: SMVIC - Shanghai Motor Vehicle Inspection Center (CN)
The matching between engine and silencer is not good and the vibration of engine is apparent.
Yes: LCOE (Laboratorio Central Oficial de Electrotecnia) Barcelona (ES)
To achieve a common device to use for different kind of L-cat vehicles.
No: ATVEA - All Terrain Vehicle Industry European Association
Test procedure is not an issue but the requirements for ISO 10844 testing track is a burden due to
the limited availabilities of such tracks.
51
B_Q3_A_Q14, “Are there any elements of the regulation that you believe are ineffective?”
B_Q3_A_Q14 replies summary: 33% of authorities and industrial stakeholders and 21% of social
partners believe that there are ineffective elements of the regulation.
Most of the social partners (68%) provide as answer to this question ‘I don’t know’.
(Figure 18)
Figure 18: Answers to Q3 of questionnaire B and Q14 of questionnaire A.
52
Indicative answers to B_Q3_A_Q14
Ineffective elements of regulation
 ASEP missing for mopeds, replacement silencers, etc. Problems with defeat devices (shutters,
parts that can be “loosen” easily). [AT]
 Testing condition in the related standard or legislation is specific which can make motorcycles
be modified by manufactures to have them pass the tests. [CN: SMVIC]
 The noise measurement is too complicated, not performable in reality. [CH: FOEN]
 Anti-tampering requirements. [PL: ITS]
 UN-R9, UN-R41, UN-R63, UN-R92: In fact that you can change silencers very easy (original to
RESS and vice versa) we have the situation, that during PTI the Original silencer is mounted and
during usual road use often a racing silencer is fitted. There is a need of information about the
legal-silencer which has to be mounted (e.g. label on the vehicle frame/main-components were the
Original-silencer or RESS is described with manufacturer, identification, noise values and remarks).
Otherwise legal enforcement is not possible. The pass-by-light-test (possibility of this is described
very roughly at UN-R41.04) needs to be detailed harmonized (how to perform and what are the
tolerances) in each UN-Regulation which deals with L-cat-vehicles above max. speed of 45 km/h.
Reason: stationary noise has lost the direct-mechanical-link to noise in motion (in fact of electronics
of the vehicles). [DE]
 The marking of component with the country code of notified body is ineffective. [ATVEA]
 TA testing for noise is too limited a criteria. See also answer to B_Q4 below. [FIGIEFA]
 Regulation of exhaust noise is that weak that our pilot on measuring and enforcing exhaust noise
failed due to the fact that even tampered mopeds stayed within the limits. [Rotterdam DCMR/EPA
Rijnmond]
 Noise emission limits. [Paris]
 In consideration of the noise some brand new motorcycles produce, the adequacy of the allowed
noise level might need to be reassessed. [ANEC]
 It may not truly reflect real world driving conditions for such vehicles, nor the ease with which an
owner may modify the vehicle. [EEA]
Enforcement problem, not regulation
 There is no TA-problem but an enforcement problem. [NL: RDW]
 The problem (for as much as this exists) is not in the regulations, but in illegal activities and lack
of enforcement. [FEMA]
53
B_Q4_A_Q15, “Would you like to make specific suggestions for improvement of the TA procedure?”
Indicative answers to B_Q4_A_Q15
Suggestions for improvement of the TA procedure
 Enforce tampering specification, improvement of control test (to be more representative) and
improvements “tools” for control. [FR: UTAC CERAM]
 The applicability of the TA procedure should be as easy that it can be handled by non-experts.
Furthermore, the possibility to control is not given. [CH: FOEN]
 _ Need for improvement at UN-R9: Quads/Tricycles have to bear an anti-tampering label at the
frame.
_ Need for improvement at UN-R63: Approach speed of L1-vehicles should be always maximum
speed.
_ Need for improvement at UN-R92: Manufacturer information about the “using area” of the
RESS are needed (via internet site of RESS-manufacturer or via UN-database: vehicle
manufacturer, vehicle type; trade name, engine capacity, engine power and model years; remarks).
This information is needed for PTI and road-side-checks of e.g. police. [DE]
 The 2011 revision of the specified ISO standard 10844 to define the track is too restrictive (i.e.
the granulometry), approved track are rare, more difficult to access time wise, more difficult to
access location wise and more expensive. [ATVEA]
 _ The test methods at the moment are legalizing exhaust systems which are too loud. This is
mainly due to the very simple approach of full throttle at 2nd or 3rd gear at the speed of 50 km/h.
This is detected by the on-board-computer of the motorcycle vehicle manufacture and effecting the
noise. This effect both original and aftermarket exhaust systems. [FIGIEFA]
_ Ensure that “Defeat Devices” or “Cycle detection” cannot be easily used, by conducting type
approval testing at a much wider range of engine/vehicle speed and loads (this effects both OE and
aftermarket systems type approval). [FIGIEFA]
 Make regulation stricter so that tampered vehicles are illegal regarding noise. Other suggestion
is to make it legal to create the ability for cities to create areas were noisy vehicles can be banned.
[Rotterdam DCMR/EPA Rijnmond]
 Reduce noise emission limits. [Paris]
 As the Volkswagen Dieselgate case has demonstrated that it is possible to defeat software
allowing it to cheat on air pollutant emission tests, it might be worth to look more closely here as well
to what is happening in practice. [ANEC]
 Random noise inspections after TA. [Norwegian Association against Noise]
 New revised TA procedure, allied to better enforcement practice, taking into account that it
should reflect real world driving conditions for such vehicles and not allow for the easy vehicle
modification by its owner. [EEA]
54
B_Q5, “How would you rate the incurred cost of the TA procedure for noise control?”
B_Q5 replies summary: The majority of authorities and industrial stakeholders (87%) characterize
the incurred cost of the TA procedure for noise control as ‘acceptable’.
(Figure 19)
Figure 19: Answers to Q5 of questionnaire B.
Indicative answers to B_Q5
Acceptable: DE Ministry of Transport and Digital Infrastructure
Compared to exhaust emission measurement, the equipment and time for measuring (2 persons) is
much cheaper. Durability doesn’t have to be done for each TA, because of using same silencers or
same principles of silencers. Costs for ISO-test-tracks are long time investments. TA fee is the
same for every kind of approval. Only measuring noise on test-track needs round about 2 hours.
Altogether, this seems to be acceptable.
Acceptable: ACEM
Compared to other TA subjects, it tends to be acceptable. In absolute terms, the TA procedure for
noise control remains a substantial cost and burden.
High: ATVEA
Because of the ISO track standard, which restricts the number of facilities to perform the test, the
cost increases.
55
B_Q6, “Would you like to make specific suggestions for improving the cost in Q5?”
Indicative answers to B_Q6
Suggestions for improvement of the TA cost
 The application of measurements should be made easier. [CH: FOEN]
 The track standard should be less restrictive. Also R9 has a provision to do the test with only 1
microphone, but the test track width dimensions are not adjusted for one mic; hence, the large test
track still required bringing more cost for testing. [ATVEA]
Market surveillance and enforcement
A_Q16, “Are you familiar with the procedure followed by market surveillance and enforcement
authorities for noise control of L-cat vehicles?”
A_Q16 replies summary: Most of the social partners (62%) are not familiar with the procedure
followed by market surveillance and enforcement authorities for noise control of L-cat vehicles.
(Figure 20)
Figure 20: Answers to Q16 of questionnaire A.
56
B_Q7_A_Q17, “Do you consider the information currently provided to market surveillance and
enforcement authorities enough to enable the effective noise control of L-cat vehicles?”
B_Q7 replies summary: Most of the authorities and industrial stakeholders consider that the
information provided to market surveillance and enforcement authorities is enough (or at least
partially) to enable the effective noise control of L-cat vehicles.
A_Q17 replies summary: However, social partners do not seem to agree, since 60% consider that it
is not enough.
(Figure 21)
Figure 21: Answers to Q7 of questionnaire B and Q17 of questionnaire A.
57
Indicative answers to B_Q7_A_Q17
Yes
 All PTWs type-approved after 17-6-1999 have appropriate labelling in their exhaust. [GR]
 The problem is not the information, but the priorities. [FEMA]
Partially
 Exhaust silencer reference are important but difficult to be used by police. [FR: UTAC CERAM]
No
 The build specification approved of the noise control system cannot be fully verified. [CN:
CNMTC]
 The stationary test is insufficient to effective noise control because the drivers illegally tune
their vehicles so that they pass the stationary test, but actually they produce more noise. [ES:
Madrid Acoustic Center]
 This is not well enough enforced. Situations may vary, but a clear improvement is required.
[EEA]
58
B_Q8_A_Q18, “Which do you consider are the main obstacles for effective noise control?”
Indicative answers to B_Q8_A_Q18
Main obstacles for effective noise control
 Several possibilities to circumvent: shutters, parts that can be “loosen” easily, etc. [AT]
 Control procedures are difficult to be used by police, stationary control test is not enough
representative of noise vehicle in motion and shadow modifications can’t be checked (e.g.
internal exhaust modifications). [FR: UTAC CERAM]
 Tricky noise regulations complicate test procedures, lack of correlation between TA and
standstill test procedure. [CH: FEDRO]
 The regulation requirements are dodged easily. [CN: SMVIC]
 The place to test, it has to be an ISO test track. [ES: LCOE]
 Motorcycles are not required to undergo a periodic roadworthiness test in Ireland. Enforcement
authorities at roadside do not have noise measuring equipment for powered two wheelers and
therefore cannot accurately determine noise level. [IE: RSA]
 Lack of influence on vehicle after sales market. [LV: CSDD]
 The main problem is not technical; L- cat vehicles placed on the market conform to the
applicable sound requirements. Consequently, noise issues come from tampered vehicles in the
aftermarket. [MT: MCCAA]
 Easy to remove parts from the silencer without the TA marking being damaged. [NO]
 Anti-tampering. [PL: ITS]
 UN-R9, UN-R41, UN-R63, UN-R92: In fact that you can change silencers very easy (original to
RESS and vice versa) we have the situation, that during PTI the Original silencer is mounted and
during usual road use often a racing silencer is fitted. There is a need of information about the
legal-silencer which has to be mounted (e.g. label on the vehicle frame/main-components were the
Original-silencer or RESS is described with manufacturer, identification, noise values and remarks).
Otherwise legal enforcement is not possible. The pass-by-light-test (possibility of this is described
very roughly at UN-R41.04) needs to be detailed harmonized (how to perform and what are the
tolerances) in each UN-Regulation which deals with L-cat-vehicles above max. speed of 45 km/h.
Reason: stationary noise has lost the direct-mechanical-link to noise in motion (in fact of electronics
of the vehicles). [DE]
 Lack of priority and budgets and man(woman)power at police forces. [NL: RDW]
 Lack of allocation of authority resources for local noise control. [ACEM]
 Better enforcement is needed to verify compliance on the side of the roads by performing more
frequent stationary sound tests. [ATVEA]
 Users of those vehicles. [CECRA]
 In-service testing should be part of the PTI. However, motorcycle PTI is not conducted in many
Member States, but should be. [FIGIEFA]
 Enforcement. [CEMR]
 Manpower, costs. [Utrecht (NL)]
 The drivers have little awareness about it. [ES: Madrid Acoustic Center]
 Complex noise control procedures, lack of limit values. [City of Barcelona]
59
 Awareness by users and industry of the effects of too much noise. Weak limits make enforcing
nearly impossible. [Rotterdam DCMR/EPA Rijnmond]
 Lack of manpower at authorities and enforceability to interdict the operation of in-use vehicles.
[City of Hamburg]
 Lack of civil servants on streets. [City of Paris]
 There is lack of policing it and stopping or fining the culprits. [ANEC]
 Time to be devoted by police forces to this issue. [FEVR]
 Lack of enforcement. [FEMA]
 Rigid enforcement regarding noise at night driving. [Norwegian Association against Noise]
 _ For urban environments, it is the ease with which younger people can use such vehicles for
transport often late at night. The convenience of these vehicles is also attractive to delivery
companies, again often used at night for food delivery. This accounts for a high proportion of
complaints to local authorities in many countries.
_ Outside of cities, the use of off road L-vehicles is commonly practiced at weekends or other
unsociable times and greatly contributes again to the high number of such complaints to local
authorities. Local enforcement can help, but it is the design character and ease of modification
that accounts for the intrusive nature of the vehicles. [EEA]
 Political will and courage. Reducing noise at the vehicle source has 0 political priority and
support and manufacturers will not spend a single € if not forced to do so. This despite the fact that
noise is a major health problem and source of quality of life reduction and studies have shown that
noise reduction at source is an order of magnitude more efficient than sound reduction effects like
sound walls etc. [AVERE]
60
B_Q9, “Do you receive complaints about the noise from L-cat vehicles?”
B_Q9 replies summary: 88% of authorities and industrial stakeholders declare that they receive
complaints about noise from L-cat vehicles (‘sometimes’ 59%, ‘almost every day’ 6%, ‘very scarcely’
23%).
(Figure 22)
Figure 22: Answers to Q9 of questionnaire B.
61
B_Q10, “What is the pattern of check and the approach that you use for noise control of L-cat
vehicles?”
Indicative answers to B_Q10
Pattern of check and approach used for noise control
 Due to missing TA documents at roadside inspection and governmental inspections, only
stationary sound level can be measured. If the stationary sound level of the replacement silencer
differs from the indication on the manufacturer's plate on the motorcycle, discussions etc. will rise.
[AT]
 Roadside checking by police. [FR: UTAC CERAM]
 Police is responsible for enforcement. Striking noise emissions are often the reason for a closer
look at the vehicle’s exhaust system. [CH: FEDRO]
 Check the inner of the exhaust pipe. [CN: CNMTC]
 All new 2/3 wheelers are subject to TA in order to be registered. No periodic inspection of 2/3
wheelers in Ireland. [IE: RSA]
 We don’t test L-cat vehicle noise for TA. At PTI we use stationary noise control according to
UN. [LV: CSDD]
 Control of TA markings, audible check, noise measurements. Roadside checks and at technical
inspection offices. [NO]
 If during PTI, excessive noise is suspected, measurement of stationary noise has to be done.
[PL: ITS]
 During PTI and road-side-checks:
1. Subjective sound assessment of the controlling person; if subjectively too loud, then go to
No. 2.
2. Measurement of stationary noise with national special requirements about constraints and
tolerances; if measured as too loud and driver/owner does not accept the result, then go to No. 3.
3. Measurement of noise in motion in accordance to EU/UN-Regulation; the cost of no. 3 shall
be borne by the person concerned, unless the vehicle is too loud. [DE]
 Type approval. [NL: RDW]
 Manufacturers have to comply with the EU regulations on noise control. [ATVEA]
 Police measurements on roads. [CECRA]
62
B_Q11, “How do you ensure that replacement silencers comply with legislation?”
Indicative answers to B_Q11
 If the TA documentation is available, the silencers will be checked against. But until this time,
the vehicle’s owner brings his vehicle into conformity with the type-approvals. [AT]
 Exhaust silencer reference checking and COP. [FR: UTAC CERAM]
 Checking the homologation marks, measurement of standstill emissions. [CH: FEDRO]
 By the approved mark. [CN: CNMTC]
 Franchisers are authorized to replace silencers by manufactures. [CN: SMVIC]
 Only increasing the test in the market, making a big effort in the market surveillance. [ES:
LCOE]
 Replacement silencers must be appropriately labelled. [GR]
 Legislative requirements are in place which require that replacement silencers are type
approved. Penalties applicable for breach of these regulations. [IE: RSA]
 Stationary noise control at periodical technical inspection. [LV: CSDD]
 The Market Surveillance Directorate (MCCAA) has reminded economic operators of their
responsibilities to ensure that products placed on the market comply with requirements through
specific communication addressed directly to them. Moreover, MSD liaises with Customs to enforce
these requirements at the border. [MT: MCCAA]
 Correct marking, documentation, check that all silencer parts are intact. [NO]
 They must have approval certificate before entering on the market. [PL: ITS]
 1. COP of e1-/E1-approved RESS.
2. Market surveillance.
3. PTI and road side checks. Remark: Compliance of RESS at PTI is difficult, because often
RESS is changed to original or legal situation;
Solution 1: An official label on the vehicle frame/main part or an official data base is
needed, where the legal mounted silencer or RESS is mentioned;
Solution 2: A harmonized detailed described pass-by-light-test is needed to check the noise
in motion. [DE]
 Type approval. [NL: RDW]
 Replacement silencers provided by ATVEA members follow the same specifications as those
fitted on the vehicles for type-approval test. [ATVEA]
 By static noise measurement with noise meter Class 2. [CECRA]
 Type approval ‘E’ marking. [FIGIEFA]
 We do a homologation approval test at testing, inspection and certification providers like TÜV
SÜD which are approved by regulatory authorities like KBA or NSAI. [Akrapovic]
63
B_Q12, “Would you like to make specific suggestions on how to improve compliance information of
replacement silencers?”
Indicative answers to B_Q12
How to improve compliance information of replacement silencers?
 Compliance information should be available via Internet to have access at roadside inspection.
[AT]
 European database for replacement silencers including all reference and practical information
on vehicle (commercial model, …). [FR: UTAC CERAM]
 Clearer designation of the type and variant of a replacement silencer. [CH: FEDRO]
 STU type approval. [CN: CNMTC]
 Silencers replaced should be approved. [CN: SMVIC]
 _ Stronger requirements could be useful for the anti-tampering systems. Modification of
approved replacement devices should not be simple.
_ A suggestion can be to adequately mark "competition reserved" components to discourage
their installation on type approved L-cat vehicles. [MT: MCCAA]
 1. COP of e1-/E1-approved RESS.
2. Market surveillance.
3. PTI and road side checks. Remark: Compliance of RESS at PTI is difficult, because often
RESS is changed to original or legal situation;
Solution 1: An official label on the vehicle frame/main part or an official data base is
needed, where the legal mounted silencer or RESS is mentioned;
Solution 2: A harmonized detailed described pass-by-light-test is needed to check the noise
in motion. [DE]
 Tried to do that already over 10 years ago, maybe update needed because of introduction
electronic databases. [NL: RDW]
 The best solution is with static measurements of more silencers on more vehicles during longer
period of driving. May be with measuring 10 silencers every 10 h of driving or 1,000 km driving in
the time period of 100 h or 10,000 km. With that we can predict noise grooving in time period during
silencer use. [CECRA]
 _ Ensure that the ‘E’ mark remains clearly visible and cannot be easily removed or ‘polished’ out.
_ Ensure that tampering of 'E' marked exhaust systems is not possible.
_ By implementing the correct control of noise emissions as part of an improved type approval
requirement (see Q4), it would negate the in-service noise problem and facilitate better methods of
market surveillance by checking for ‘E’ marking as part of the PTI test (see Q8 and Q13). [FIGIEFA]
 Maybe to introduce a special sticker with sign which indicates on a box that a product is
compliant with noise regulations. An awareness campaign for customers to know noise
regulations and labelling of compliant products. Similar to EU tire rating. [Akrapovic]
64
B_Q13_A_Q19, “Would you like to make specific suggestions for improvement of the market
surveillance, monitoring and enforcement procedure?”
Indicative answers to B_Q13_A_Q19
Suggestions for improvement of the market surveillance, monitoring and enforcement procedure
 Can be done with amendment of the 1958 agreement only. [AT]
 Randomly sampling from the market and check the consistency. [CN: CNMTC]
 Regular market surveillance by selective examinations. [CN: SMVIC]
 Coordination between the TAAs. [ES: LCOE]
 L-category vehicles should be more silent in general and the control procedure should be easier
to perform and be close to reality. [CH: FOEN]
 Anti-tampering measures. [PL: ITS]
 PTI and road side checks. Remark: Compliance of RESS at PTI is difficult, because often
RESS is changed to original or legal situation;
Solution 1: An official label on the vehicle frame/main part or an official data base is needed,
where the legal mounted silencer or RESS is mentioned;
Solution 2: A harmonized detailed described pass-by-light-test is needed to check the noise in
motion. [DE]
 See current legislation in Brussels: 167/2013 and 168/2013 for market surveillance. [NL: RDW]
 Perform more frequently stationary sound tests to verify compliance on the side of the roads.
[ATVEA]
 Market surveillance must be conducted by appropriately trained and equipped MS
authorities/PTI test centres and not be conducted by organisations who have conflicts of interest
(i.e. market their own competitive products). [FIGIEFA]
 National regulations should be unified with EU regulations, so that we have to use only one
regulation like UN ECE. [Akrapovic]
 Include the motion test in the control of the vehicles in use. [ES: Madrid Acoustic Center]
 Enforcement of regulations. Police has other priorities. [City of Hague]
 Market surveillance (checking shops on illegal products) and enforcement (stopping loud
motorcycles in the street and measure sound levels) should be increased. [ANEC]
 Better empowerment and communication between relevant authorities to avoid loopholes in
the legislation regulating noise from such sources. [MT: EPA]
 Better regulation is the key. Quieter vehicles, with limited modification options, and local
monitoring of design and use practices can help. Some cities and regions are introducing incentives
for electrically powered two wheeled vehicles, particularly aimed at delivery companies and young
people. Make the market more attractive for silent eco-friendly vehicles and they will gain in
popularity. This needs to also make the traditional powered vehicles less attractive, with taxes,
operating restrictions etc. [EEA]
Other issues
A_Q20_B_Q20, “Please provide any other comments or remarks not addressed above.”
Indicative answers to A_Q20_B_Q20
65
Any other comments or remarks not addressed above
 Make products supply for illegal tuning illegal in itself. [City of Utrecht]
 L-vehicles are the main source of complaints in Paris (for environmental noise). [City of Paris]
 L-vehicles are very common in Europe, yet pan-European assessments of noise impact by
Directive 2002/49/EC do not generally include these vehicles. Therefore, the impact assessment is
greatly underestimated. A knock on effect is that policy measures on noise control, such as this
one, are not fully informed. Consideration should be given to allowing easier quantification of the
problem from manufacturers (source data), national governments (noise calculations), and the EC
(specifying how such vehicles should be incorporated into an assessment can be a helpful first
step). [EEA]
 Most problems in rural areas by touring of motorcyclists in large amounts of vehicles. [NL: RIVM]
 Electric vehicles make virtual no noise at low speed, this is what we want from transport in the
future especially in cities; however, there is actively lobbying to let EV’s make noise, especially by
organizations which represent combustion engine interests, reason perhaps to reduce the EV
advantage? [AVERE]
 The less noise the better! [KU Leuven]
 Due to the complexity of the measuring methods, enforcement in the field should only be
considered in case of official complaints. [BE]
 _ L-cat vehicles are in general too loud (even without tampering), stricter limiting values would
be necessary.
_ Noise controls from L-cat vehicles are not possible to perform.
_ Political standing of noise pollution is very low. [CH: FOEN]
 _ The main problem comes from the tampered motorcycles.
_ Make it impossible to modify the approved exhausts is quite complicated, and because of the
"competition reserved" components, it could also result useless.
Currently the main solution to contain the level of sound emissions would seem to be
intensifying the level and quality of controls on the roads. [MT: MCCAA]
 There is no type approval problem but an enforcement problem, lowering the limits may have an
adverse effect. [NL: RDW]
 We support unification of all noise regulations in EU, especially implementation of ECE noise
regulations. We also support strict implementation of all noise regulations without exceptions
regarding compliant products in all EU countries. [Akrapovic]
66
A_Q21_B_Q21, “Please provide references for further details to the extent possible (documents,
literature, practical examples, own measurements, etc.).”
Indicative answers to A_Q21_B_Q21
References for further details
 Results of mopeds pilot to be sent later. [Rotterdam DCMR/EPA Rijnmond]
 Report on noise action plan in Paris. [City of Paris]
 3 references and 2 contact points at JRC provided. [ICCT]
 Type approval documentation (i.e. drawings and applicable motorcycle types to the
replacement silencer, stationary noise level) should be available via internet. [AT]
 Report on the noise behaviour of L-cat vehicles. Some measurements were performed in
the city of Zurich. Unfortunately, the report is only available in German, French and Italian.
http://www.astra.admin.ch/dienstleistungen/00125/00416/00431/index.html?download=NHzLpZ
eg7t,lnp6I0NTU042l2Z6ln1acy4Zn4Z2qZpnO2Yuq2Z6gpJCEdYF8hGym162epYbg2c_JjKbNoK
Sn6A--&lang=de [CH: FOEN]
 In working more than 10 years at a technical service on the field of L-category type
approval, many motorcycle owners came and ask for higher sound (legal with RESS or the
consequences if they are driving with an illegal silencer). [DE]
 My view is based upon a.o. 40 years of motorcycle driving. [NL: RDW]
 3 references provided. [ACEM]
 https://www.umweltbundesamt.de/sites/default/files/medien/377/dokumente/steven.pdf
[FIGIEFA]
67
2.3 Summary and conclusions
The conclusions presented in this chapter are drawn as a result of processing the questionnaires
and analysing the responses given. Specifically, for each one of the four categories shown below,
the corresponding conclusions are mainly based on (but not strictly limited to) answers to specific
questions (see section 2.2.2):
 “Environmental and social aspects of noise pollution from L-category vehicles” conclusions:
from answers to questions A_Q1 to A_Q12 and B_Q14 to B_Q19 (in “Environmental and
social aspects of noise pollution from L-category vehicles” part of section 2.2.2).
 “Market surveillance and enforcement” conclusions: from answers to questions A_Q16 to
A_Q19, B_Q7 to B_Q10, and B_Q13 (in “Market surveillance and enforcement” part of
section 2.2.2).
 “Regulations and type approval” conclusions: from answers to questions A_Q13 to A_Q15
and B_Q1 to B_Q6 (in “Technical issues related to noise control regulations” part of section
2.2.2).
 “Replacement silencers and compliance with legislation” conclusions: from answers to
questions B_Q11 to B_Q12 (in “Market surveillance and enforcement” part of section 2.2.2).
From the above, it can be seen that all answers have been used to come up with the final
conclusions. Answers to questions A_Q20 to A_Q21 and B_Q20 to B_Q21 (in “Other issues” part
of section 2.2.2), which are not mentioned in any of the four bullets above, were used wherever and
if appropriate in any of the four categories of conclusions, since these questions were only
supplementary to the questionnaire (provision of any other comments or remarks not addressed
with other questions, and provision of references for further details).
Before presenting the conclusions, a short assessment of this task is provided below.
In total, there were 44 filled in questionnaires received, which is ~36% of the number of entities
contacted (123). The responses are equally split between: i) social partners (22), and ii) authorities
and industrial stakeholders (22), which is a very good indicator of their representativeness and of
the quality of the final outcomes of this public consultation procedure.
In general, the questionnaire has been filled in by a wide range of stakeholders in different and nonoverlapping fields, i.e. national responses (from technical services, type approval authorities,
transport departments, market surveillance and enforcement authorities), industry and
manufacturers, cities and regions, and various organizations (environmental, noise concerned,
motorcycle, consumer, etc.).
The main conclusions are now presented as follows.
Environmental and social aspects of noise pollution from L-category vehicles
1. Noise perceived from L-category vehicles is considered to still be a significant problem for many
European citizens. Complaints about noise from these vehicles are quite frequent and the
problem is more intense mostly in urban areas during all periods of the year; rural areas are also
affected especially during weekends and holiday periods by touring groups of motorcyclists.
2. Noisy L-category vehicles are characterized as ‘disturbing’ or ‘rather disturbing’ by almost all
participants of the survey; furthermore, half of the participants consider the noisy vehicles even
as a threat, because the noise distracts their attention when cycling or walking. This is more or
less consistent with studies which have shown that noise is a considerable health problem and
a factor affecting quality of life.
3. Most of the perceived noise is considered to come from tampered vehicles and especially
motorcycles; however, mopeds and other L-category vehicles are also considered to contribute
68
to the noise problem. The main noise responsible are considered to be the drivers who tune or
modify the exhaust system or use special silencers on their vehicles (e.g. young enthusiasts
enjoying in producing as much sound emission from their vehicle as possible especially when
driving at night).
4. Concerning the regulations, the problem lies mainly their weak enforcement and less in the noneffectiveness of the regulations as such. Hence, the key issue is that the non-original silencer
industry produces devices which may be easily to alter, with several removable inserts to
attenuate noise.
5. From the riders/drivers of the survey, more than half of them report that their vehicle needs to
be more silent. The percentage of L-cat vehicle owners that actually replace the silencer is
believed to be around 23%3. The main reason for doing so, is for improved noise, better looks,
more power, or other reasons (increased noise, less weight, less cost, unavailability of original
silencer e.g. after an accident).
6. When it comes to spending more money for better noise control, there seems to be a
contradiction in the findings of the survey. The majority (85%) of the candidate buyers of a
motorcycle say that they would spend more money when purchasing their vehicle for better
control of its noise (with some concerns that this would not lead to loss of power); however, the
authorities and industrial stakeholders estimate that the percentage of customers who would be
willing to pay more for better noise control is only 25%.
7. The majority (80%) of the participants of the survey would like to see more done for better noise
control on the following:
 More anti-tampering measures, better market surveillance and better enforcement of
regulations (e.g. by police control, roadside checks, more effective periodic technical
inspection checks).

Improve in-use compliance sound emission tests to better reflect real driving road
conditions and better check of sound emission of vehicles in motion.
 Prohibition of defeat devices and of easy tampering by proper design measures.
 Impede removal or modification of individual parts from an approved silencer.
 Regarding sound limits, it is acknowledged that more strict limits in general can help
towards reducing noise, but there are some concerns that this measure is not sufficient in
itself (i.e. if not combined with better enforcement in practice).
Market surveillance and enforcement
1. A general remark is that the main problem is identified in the lack of adequate market
surveillance and enforcement of regulations, and not so much in the type-approval procedure
itself. Hence, a clear improvement is required on this field.
2. Most of the authorities and industrial stakeholders consider that the information currently
provided is enough (or at least partially) to enable the effective noise control (e.g. with
appropriate labelling in the exhaust). However, social partners do not seem to agree with this
and they focus mostly on the fact that drivers can easily tune their vehicles to pass the stationary
test, but actually produce more noise during usual use on the road.
3. The approach followed in periodic technical inspection and roadside checks by police (in some
countries) is more or less as below: first, there is a subjective sound assessment of the
controlling person; if, subjectively, the sound is assessed as too loud, then a closer look at the
3
Rough approximation based on authorities and industrial stakeholders’ opinion. Same question to social partners
gave a 14%, but this is considered as a non-safe conclusion due to the very low response of the questionnaire
recipients.
69
vehicle’s exhaust system is required and a measurement of stationary noise is made; if it is
measured as too loud and driver/owner does not accept the result, then a measurement of noise
in motion is made in accordance to regulations.
4. However, this approach is not followed by all countries; in general, the main obstacles for
effective noise control are summarized as follows:
 Periodic technical inspection and in-service conformity testing is not conducted in all EU
Member States.
 The stationary control test is not always representative of sound emission from the vehicle
in motion under real driving conditions.
 There are many possibilities to circumvent the test, i.e. such as by shutters, parts that can
be ‘loosened’ or removed easily without the TA marking being damaged, etc.; shadow
modifications can’t always be checked (e.g. internal exhaust modifications).
 As a result of the fact that silencers are easy to replace (original to replacement unit and
vice versa), sometimes a racing silencer is fitted for normal road use, whilst the original
silencer is temporarily refitted during periodic technical inspection.
 Complex noise control procedures are not always easy for police to apply; moreover, there
is often lack of staff, budget, resources, and equipment for effective noise control.
5. The general directions and suggestions for improvement of the market surveillance, monitoring
and enforcement procedure are summarized as follows:
 In general, market surveillance (e.g. random sampling from the market, checking for illegal
products) and enforcement (e.g. stopping loud motorcycles on the street and measuring
sound levels) should be increased and given higher priority.
 Market surveillance must be conducted by appropriately trained and equipped
authorities/PTI test centres to avoid being conducted by organisations that might present
conflicts of interest.
 The control procedure and measuring methods should be simple and easy to perform in
order to be more effectively used (e.g. by police) during enforcement. There is also a need
for information on the type-approved silencer which should be present (e.g. label on the
vehicle frame/main part with manufacturer, identification, noise values and remarks); the
verification of this information should be easy to perform.
 Stationary sound tests should be more frequent to verify in-use compliance; furthermore,
in-use testing should be part of the PTI and include testing of the vehicle in motion (e.g.
with a detailed harmonized pass-by noise testing).
 Better empowerment and communication between all relevant authorities in the direction of
unified legislation and testing of vehicles in motion for roadside check or PTI, in addition to
loophole avoidance in the legislation.
Regulations and type approval
1. Most of the participants characterize the overall TA procedure for noise control as ‘easy to follow’
and do not encounter specific technical complications. Some concerns have been expressed
about the ISO 10844 test track requirements, due to limited availability of such tracks. In any
case, there is also a small, still non-negligible, percentage of participants who suggest that the
legislation can be improved towards quieter vehicles without complicating the legislative
procedure.
70
2. The incurred cost for the TA is characterized as ‘acceptable’ (i.e. compared to other TA
subjects); again, there were some concerns about the cost for ISO test tracks, which are
considered a long term investment.
3. The main elements of regulation which are considered to be ineffective are the following:
 Anti-tampering measures are insufficiently enforced.
 Type approval testing may not truly reflect real world driving conditions.
 The simplistic approach of the test may still allow for defeat devices and cycle detection;
hence, it may still be possible for the on-board computer of the vehicle to detect that it is
being tested.
 Noise measurement is too complicated and not easy to perform in practice (e.g. roadside
checks by police).
 Perhaps noise limits should be more strict, considering the noise produced by some brand
new motorcycles.
4. Specific suggestions for improvement of the TA procedure are summarized below:
 Enforce anti-tampering measures (e.g. anti-tampering label at the frame), improve control
test to be more representative of real driving conditions, and prevent easy vehicle
modification by its owner.
 Tampered vehicles should be characterized as illegal regarding noise.
 Ensure that defeat devices or cycle detection cannot be easily used, by conducting type
approval testing at a much wider range of engine/vehicle speed and loads (for both OEM
and aftermarket systems type approval).
 The applicability of the TA procedure should be made easier and allied to better
enforcement practice; type approval documentation should be available via Internet.
Replacement silencers and compliance with legislation
1. In general, the compliance of replacement silencers with legislation is ensured with the ‘E’
approval markings and conformity of production, following the same specifications as those fitted
on the vehicles for the type-approval test.
2. However, check of RESS compliance during PTI is sometimes difficult, because often RESS is
replaced with the original before conducting the test. A solution to this, as well as other
suggestions for improvement of compliance information of replacement silencers, are
summarized below:
 Use an official label on the vehicle frame/main part or an official electronic database (e.g.
available via Internet), where the legal mounted silencer or RESS is mentioned and all
reference and practical information is included (i.e. vehicle manufacturer, vehicle type,
trade name, engine capacity, engine power, model years, remarks).
 Maybe a special sticker with sign indicating on a box that a product is compliant with noise
regulations could help towards this, together with an awareness campaign for customers
on labelling of compliant products (e.g. similar to EU tyre rating).
 Ensure that the ‘E’ mark remains clearly visible and cannot be easily removed or ‘polished’
out; moreover, ensure that tampering of 'E' marked exhaust systems is not possible.
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3
Amendments to UN Regulations
The objective of proposal for amendments to the UN Regulations has been to:
 Ensure that the UN Regulations Nos. 9, 63 and 92 provide at least the same or, favourably,
improved level of stringency with respect to type-approval, market surveillance and
enforcement requirements, concerning sound emissions, as the EU regulations and provide
the technical background required for the later introduction of Euro 5 sound level limits.
 Assess if those three UN Regulations contain the necessary references to and deliver the
minimum test results level which are used for type-approval, market surveillance and
enforcement purposes in the EU, concerning sound emissions.
A further aspect is related to additional sound emission provisions (ASEP), which are intended to
ensure that the sound emissions in real world driving are in line with the sound levels measured
during type approval. Such provisions are already laid down in ECE R 41.
The amendments described in the following paragraphs of this report were delivered to the GRB as
working documents and presented to and adopted by the GRB at the 64th meeting in September
2016 in Geneva.
3.1 Regulation 9
The final version of the amendment proposal for this regulation is annexed to this report.
3.1.1 Editorial amendments


The word “noise” was replaced by “sound” or “sound emission” except for background noise
in order to bring it in line with UN Regulation No. 41-04.
Whenever the word “speed” is used throughout the regulation, it is specified whether it is
engine speed or vehicle speed.
3.1.2 Amendments in paragraph 2, Definitions
“Rated maximum net power” was amended as follows:
2.3.
“Rated maximum net power, Pn, kW”
For vehicles with a combustion engine rated maximum net power
means the rated engine power as defined in ISO 4106:2012.
The symbol Pn denotes the numerical value of the rated maximum
net power expressed in kW.
2.2.5 “Number and ratio of gears” was replaced by “Drive train, in particular the number and ratios
of the gears of the transmission and the final ratio”, which is more precise.
In 2.7 "Exhaust or silencing system component" the following sentence was added (taken from
UN Regulation No. 63):
If the engine is fitted with an intake device (air filter and/or an intake
sound absorber essential in order to ensure conformity with sound
level limits), this device shall be considered to be a component of
the same importance as the exhaust system proper, and be
included in the list referred to in paragraph 3.2.2. below and carry
the markings prescribed in paragraph 4.1. below.
In 2.8 the kerb mas was replaced by reference mass and 2.9 “Test mass” was added as follows:
72
The test mass is the reference mass plus the combined mass of
the driver and test equipment.
The combined mass of the driver and test equipment used on the
vehicle shall not be more than 90 kg nor less than 70 kg. Weights
shall be placed on the vehicle, if the 70 kg minimum is not
reached. The symbol mt denotes the test mass expressed in kg.
The following text was taken out from paragraph 2.7 old and was moved to a new paragraph
2.10 as follows:
“Maximum vehicle speed” means the maximum vehicle design speed measured
according to ISO 7116:2011 for L2 category vehicles and according to ISO 7117:2010
for L4 and L5 category vehicles.
The references to the ISO standards were updated to the latest versions and the existing text
was modified in order to also cover L2 category vehicles appropriately.
The symbol vmax was added for easier reference in the text and in equations.
3.1.3 Amendments in paragraph 6, Specifications
In paragraph 6.2.1.1 the following text was added to this paragraph in order to prevent loopholes
in the sound emission requirements:
“If the vehicle has user selectable software programs or modes which affect the sound emission
of the vehicle, all these modes shall be in compliance with the requirements in this paragraph.
Testing shall be based on the worst case scenario.”
Furthermore, requirements for hybrid electric vehicles were added according to the EU Directive
134/2014/EU as follows:
For hybrid electric vehicles, the tests shall be performed twice under the
following conditions:
(a) condition A: The batteries shall be at their maximum state of charge;
if more than one ‘hybrid mode’ is available, the most electric hybrid
mode shall be selected for the test;
(b) condition B: The batteries shall be at their minimum state of charge;
if more than one ‘hybrid mode’ is available, the most fuel-consuming
hybrid mode shall be selected for the test.
The final result is the highest of the test results for conditions A and B.
This is necessary, because L5 category hybrid electric vehicles exist on the European market.
Paragraph 6.2.1.3 containing the limit values was amended as follows and the limit values were
moved to a new annex 4:
6.2.1.3.
The sound level measured by the method described in paragraph
3.1. of Annex 3 to this Regulation when the vehicle is in motion
shall not exceed the limits prescribed (for new vehicles and new
exhaust or silencing systems) in Annex 4 to this Regulation for
the category to which the vehicle belongs.
Paragraph 6.3 was amended in order to bring it in line with UN Regulation No. 41-04 as follows:
6.3
Additional requirements,
6.3.1
Tampering protection provisions,
In this paragraph the word “easily” was deleted in order to strengthen
the requirement.
6.3.2
Multi-mode exhaust or silencing systems,
73
In this paragraph the words “or electronically” and “rider selectable”
were added to cover not only manually adjustable multi-mode exhaust
or silencing systems but also more advanced electronically adjustable
systems.
In Paragraph 7, sub-paragraph 7.1.2. the term “Technical Testing Service” was replaced by
“Technical Service responsible for conducting the tests” being more comprehensible.
The sub-paragraphs 11.7 and 11.8 were added in paragraph 11 “Transitional provisions” in
agreement with ECE/TRANS/WP.29/2015/59, which was already adopted by WP 29.
3.1.4 Annex 1
Point 5. was renamed to “combustion engine” and supplemented by the sub-points 5.1 Engine
manufacturer and 5.2 Engine type. The original text under point 5 was put under 5.3 and points 6
to 9 were renamed to 5.4 to 5.7.
A new point 6 “electric motor (if applicable)” was added with two sub-points 6.1 “Make” and 6.2
“Type” dealing with information for the electric motor in case of a hybrid electric vehicle. This
information is necessary for the determination of a vehicle type in case of a hybrid electric vehicle.
Points 10 to 12 dealing with information about the transmission were merged under the new point
7 “Transmission” and were supplemented by 7.1 “Make” and 7.2 “Type (manual, automatic, CVT)”.
The old points 10 to 12 were renumbered to 7.3 to 7.5.
The following points (old 13 to 18) were renumbered to 8 to 15.
Point 15 (18 old) “Sound levels” was restructured to make it more comprehensible. The required
information was put under sub-points 15.1 to 15.4.
A new point 16. “In use compliance reference data” and the sub-points 16.1 to 16.3 were added
specifying this data. The aim is to allow not only stationary in use compliance tests but also more
effective in use compliance tests with the vehicle in motion analogous to Regulation No. 41-04.
The old point 19. was deleted in accordance with ECE/TRANS/WP.29/2015/59.
The remaining points (old 20 to 29) were renumbered to 17 to 26.
3.1.5 Annex 3
The header was drafted more precisely.
2.1.
Test site, weather conditions and background noise level correction
The whole paragraph was restructured in order to make the text more
comprehensible.
The requirements for test site, weather conditions and background
sound level correction were put to this paragraph.
Sub-paragraph 2.1.1 got the header “Test site” and the text was
supplemented according to ECE/TRANS/WP.29/2015/59.
The figure in the new sub-paragraph 2.1.2 “Weather conditions and
background noise correction” was deleted, because it was not in line
with the table, which contains the correct values.
2.2.
Condition of the vehicle
2.2.1
General conditions
The vehicle shall be supplied as specified by the vehicle
manufacturer (unchanged).
In the following sentence the amendments are highlighted in bold:
74
Before the measurements are started, the vehicle shall be brought
to its normal operating conditions as regards:

Temperatures;

Tuning;

Fuel;

Sparking
plugs,
appropriate).
carburettor(s),
etc.,
(as
If the vehicle is fitted with fans with an automatic actuating
mechanism, this system shall not be interfered with during the
sound measurements. (unchanged)
The following sentence was added:
If the vehicle is equipped with devices which are not necessary for
its propulsion, but which are used whilst the vehicle is in normal
service on the road, those devices shall be in operation in
accordance with the specifications of the manufacturer.
For vehicles having more than one driven wheel, only the drive
provided for normal road operation may be used. If the vehicle is
fitted with a trailer or a semi-trailer, this shall be removed for the
purposes of the test. (unchanged)
2.2.2
Test mass of the vehicle
The vehicle shall be tested with its test mass as defined in
paragraph 2.7 of this Regulation (amendment).
2.2.3
Tyre selection and condition (unchanged)
Paragraph 3.1 of annex 3 “Methods of testing” was restructured and amended as follows:
3.1.
Measurement of the sound emission of the vehicle in motion
3.1.1.
Test arrangement and microphone positions
3.1.1.1.
The test arrangement is shown in figure 1.
Two lines, AA' and BB', parallel to the microphone line PP' and
situated respectively 10 m forward and 10 m rearward of that line
shall be marked out on the test track.
3.1.1.2.
The distance of the microphone positions from the line CC', on the
microphone line PP', perpendicular to the reference line CC' on the
test track (see Figure 1), shall be 7.5 ± 0.05 m.
The microphones shall be located 1.2 ± 0.02 m above the ground
level. The reference direction for free-field conditions (see IEC
61672-1:2002) shall be horizontal and directed perpendicularly
towards the path of the vehicle line CC'.
Figure 1: Measuring positions for vehicles in motion
Figure 1 was moved from appendix 1 to this place in 3.1.2
3.1.2
Acceleration test execution, approach vehicle speed and gear use
3.1.2.1.
The vehicle shall approach line AA' at an initial steady vehicle
speed as specified below. When the front of the vehicle reaches
line AA' the accelerator handle shall be fully opened as quickly as
practically possible and kept in that position until the rear of the
vehicle reaches line BB'; the accelerator handle shall then be
returned as quickly as possible to the idle position. The vehicle
75
speed achieved, when the rear of the vehicle reaches the line BB’
is called vBB’.
Also the following sentence was added and the paragraphs following this sentence were
moved to this place:
The engine speeds corresponding to vAA’ and vBB’ in a specific
test condition are called nAA’ and nBB’.
In the case of articulated vehicles consisting of two nonseparable units regarded as a single vehicle, the semi-trailer shall
be disregarded in determining when line BB' is crossed.
For all measurements, the vehicle shall be driven in a straight line
along the test track in such a way that the track of the median
longitudinal plane of the vehicle is as close as possible to the
line CC'.
The following paragraphs contain text from the current regulation but the paragraphs were
rearranged and the text amended, where necessary:
3.1.2.2
Determination of the approach vehicle speed and the gear use
3.1.2.2.1
Vehicle with no gearbox
The vehicle shall approach line AA' at a steady vehicle speed vAA’
corresponding either, in terms of engine speed, (min-1) to 75 per
cent of the rated engine speed as defined in paragraph 2.4 of this
Regulation, or to 75 per cent of the maximum engine speed
permitted by the governor, or to 50 km/h, whichever is the lowest.
3.1.2.2.2
Vehicles with manual transmissions, automatic transmissions, or
transmissions with continuously variable transmission ratios
(CVT's) tested with locked gears
If the vehicle is fitted with a dual mode transmission (e.g. low and
high), the mode for normal on-road operation shall be selected.
If the vehicle is fitted with a gearbox with two or three or four
forward gears or the same number of lockable gears in automatic
transmission or in CVT, the second gear shall be used. If the
gearbox has more than four forward gears or the same number of
lockable gears in automatic transmission or in CVT, the third gear
shall be used.
The vehicle shall approach line AA' at a steady vehicle speed vAA’
corresponding either, in terms of engine speed, to 75 per cent of
the rated engine speed as defined in paragraph 2.4 of this
Regulation or to 75 per cent of the maximum engine speed
permitted by the governor, or to 50 km/h, whichever is the lowest.
If, by following the above procedure, the engine speed nBB’,
achieved when the rear of the vehicle passes the line BB’, exceeds
the rated engine speed as defined in paragraph 2.4 of this
Regulation, the first higher gear (or locked gear) which ensures that
the rated engine speed is no longer exceeded up to the line BB' of
the measurement area should be used instead of the second or
third gear.
Auxiliary step-up ratios ("overdrive") shall not be engaged.
3.1.2.2.3.
Vehicles with automatic transmissions, adaptive transmissions or
transmissions with variable transmission ratios tested with nonlocked gears
The gear selector position for full automatic operation shall be
used.
76
Where several full automatic operation modes are available (e.g.
economic, sporty), that mode shall be selected which results in the
highest average acceleration of the vehicle between lines AA' and
BB'.
The test may then include a gear change to a lower gear and a
higher acceleration. A gear change to a higher gear and a lower
acceleration is not allowed. In any case, a gear change to a gear
which is typically not used at the specified condition in urban traffic
shall be avoided.
Therefore, it is permitted to establish and use electronic or
mechanical devices, including alternative gear selector positions,
to prevent a downshift to a gear which is typically not used at the
specified test condition in urban traffic. The functionality of the
devices shall be described in the communication form.
The vehicle shall approach the line AA' at a steady vehicle speed
vAA’ of 50 km/h or at 75 per cent of its maximum vehicle speed as
defined in paragraph 2.8 of this Regulation, whichever is the lower.
3.1.3
Sound level determination
The following amendments are proposed according to UN Regulation No. 41-04. In the
current text the individual measurement results are reduced by 1 dB and rounded to the
nearest integer and then the arithmetic average is calculated as the final result. The method
in UN Regulation No. 41-04 is more appropriate and this method is also used in paragraph
3.1.3 of annex 3.
The maximum sound level recorded at each side of the vehicle
shall be reduced by 1 dB(A) to account for measurement
inaccuracy and mathematically rounded to the nearest first decimal
place (e.g. XX.X). These values constitute the results of the
measurement.
The measurement will be invalid if an abnormal discrepancy is
recorded between the peak value and the general sound level.
At least two valid measurements shall be made on each side of the
vehicle.
The measurements shall be considered valid if the difference
between the results of the two consecutive measurements on the
same side of the vehicle is not more than 2 dB(A).
Preliminary measurements may be made for adjustment purposes,
but shall be disregarded for the determination of the measurement
results.
3.1.4
Calculation of the final test result
The final test result is the average of the four test results rounded
off to the nearest whole decibel. If the figure following the decimal
point is between 0 and 4, the total is rounded down and if it is
between 5 and 9, it is rounded up.
In case of hybrid electric vehicles, the final result is the highest of
the test results for conditions A and B as described in paragraph
6.2.1.1 of this Regulation.
Paragraph 3.2 of annex 3 “Measurement of the sound emitted by stationary vehicles (conditions
and method of measurement for testing vehicles in service)” was amended as follows:

The header of paragraph 3.2 was modified to read: “Measurement of the sound emitted by
stationary vehicles (for testing of vehicles in use)”.
77

The header of paragraph 3.2.1 was modified to read: “Sound pressure level close to the
outlet(s) of the exhaust system”.

“in service” was replaced by “in-use”.

Figures 2 and 3 were moved from the appendices to the paragraph where they are
referenced.

½ was replaced by “50 per cent”.

¾ was replaced by “75 per cent”.

S was replaced by nrated with a reference to the definitions (as defined in paragraph 2.4 of
this Regulation).
A new paragraph 4 was added in annex 3 in accordance with UN Regulation No. 41-04 as
follows:
4.
Sound from the vehicle in motion (data reported to facilitate in
motion testing of the vehicle in use).
4.1.
A test procedure for in-use compliance tests may be defined by a
Contracting Party, taking due account of any differences from the
test conditions used at type-approval.
4.2.
In order to facilitate in-use compliance test of vehicles, the following
information relating to the sound pressure level measurements
carried out in accordance with paragraph 3.1 of Annex 3 for the
vehicle in motion is referred to as in-use compliance reference
data:
4.3.
(a)
Gear (i) or, for vehicles tested with non-locked gear ratios,
the position of the gear selector chosen for the test;
(b)
The vehicle speed vAA’ in km/h at the beginning of the full
throttle acceleration test in gear (i); and
(c)
The final test result in dB(A) as determined according to
paragraph 3.1.4 of this annex.
The in-use compliance reference data shall be entered in the
communication form conforming to annex 1.
Paragraph 5 was amended as follows:
In paragraphs 5.1.3 and 5.1.4

References to ISO standards were made to the latest versions.

Figure 4 was integrated in paragraph.

In the descriptions related to the tables “category of vehicle” was replaced by “engine
capacity class of the vehicle”

“engine speed (S) at which the engine develops maximum power” was replaced by “the
rated engine speed as defined in paragraph 2.4 of this Regulation”

“%” was replaced by “per cent”,

“S” was replaced by “nrated”
Paragraph 5.2.2 was replaced by the following text:
5.2.2
All original silencers shall bear at least the following:
(a)
the ‘E’ mark followed by the reference to the country which
granted the type-approval;
78
(b)
the vehicle manufacturer’s name or trademark; and
(c)
the make and identifying part number.
This reference shall be legible, indelible and visible in the position
at which it is to be fitted.
3.1.6 Annex 4
A new annex 4 was added, containing the limit values for the three vehicle categories:
Maximum sound level limits (new vehicle)
Vehicle category
Maximum sound-level values in
dB(A)
L2
76
L4
80
L5
80
3.1.7 Annex 5
The old annex 4 was renumbered to annex 5 but remained unchanged, because it will be replaced
by a reference to ISO 10844:2014 in future.
The footnote "The specifications for the test site reproduced in this annex are valid until the end of
the period indicated in paragraph 11.8. of this Regulation" was added, in line with paragraph 2 of
Annex 3.
79
3.2 Regulation 63
The final version of the amendment proposal for this regulation is annexed to this report.
3.2.1 Editorial amendments
 The word “moped” was replaced by “vehicle”.
 The word “noise” was replaced by “sound” or “sound emission” except for background noise
in order to bring it in line with UN Regulation No. 41-04.
 Whenever the word “speed” is used throughout the regulation, it is specified whether it is
engine speed or vehicle speed.
3.2.2 Amendments in paragraph 2, Definitions
 “Rated maximum net power” and “rated engine speed” was added.
 “Number and ratio of gears” was replaced by “Drive train, in particular the number and ratios
of the gears of the transmission and the final ratio”, which is more precise (see 2.2.2),
 “Reference mass” and “test mass” were added.
 “Maximum vehicle speed” was added.
3.2.3 Amendments in paragraph 6, Specifications
Paragraph 6.3 was amended in order to bring it in line with UN Regulation No. 41-04 as follows:
6.3 Additional requirements
6.3.1 Tampering protection provisions
6.3.2 Manually adjustable multi-mode exhaust or silencing systems
6.3.3 Prohibition of defeat devices
3.2.4 Transitional provisions
The sub-paragraphs 10.7 and 10.8 were added to the transitional provisions in agreement with
ECE/TRANS/WP.29/2015/64, which was already adopted by WP 29.
3.2.5 Annex 1
Point 14 “Number of gears” was renamed to “Transmission” and new sub-points 14.1 “Make”, 14.2
“Type (manual, automatic, CVT)” and 14.3 “Number of gears” were added. The existing sub-points
14.1 and 14.2 were renumbered to 14.4 and 14.5.
The existing text in point 20. was deleted in accordance with ECE/TRANS/WP.29/2015/64 and
replaced by a new point 20. “In use compliance reference data” and the sub-points 20.1 to 20.3
specifying this data. The aim is to allow not only stationary in use compliance tests but also more
effective in use compliance tests with the vehicle in motion analogous to UN Regulation No. 41-04.
3.2.6 Annex 3
Paragraph 2 of annex 3 “Conditions of measurement” was restructured and amended as follows:
2.1.
Test site, weather conditions and background noise
correction
2.1.1.
Test site
80
The following sentence was added, taken over from ECE/TRANS/WP.29/GRB/2015/5:
The surface of the test track shall conform to the requirements of
Annex 5 to this Regulation or in accordance to ISO10844:2014.
After the end of the period indicated in paragraph 10 of this
Regulation only ISO 10844:2014 shall be used as reference.
The following paragraphs were rearranged from the current version of UN Regulation No.
63, renumbered and suitably amended as follows:
2.1.2.
Weather conditions and background noise correction
2.2.
Condition of the vehicle
2.2.1
General condition
Before the measurements are started, the engine shall be brought
to its normal operating conditions as regards:

Temperatures;

Tuning;

Fuel;

Sparking plugs, carburettor(s), etc., (as appropriate).
If the vehicle is fitted with fans with an automatic actuating
mechanism, this system shall not be interfered with during the
sound measurements.
If the vehicle is equipped with devices which are not necessary for
its propulsion, but which are used whilst the vehicle is in normal
service on the road, those devices shall be in operation in
accordance with the specifications of the manufacturer.
The following text is already in the regulation, but the paragraphs are amended:
2.2.2.
Test mass and tyre selection
2.2.2.1.
The vehicle shall be tested with its test mass as defined in
paragraph 2.11 of this Regulation.
2.2.2.2
Tyre selection and condition
The tyres shall be appropriate for the vehicle and shall be inflated
to the pressure recommended by the vehicle manufacturer for the
test mass of the vehicle.
The tyres shall be selected by the vehicle manufacturer and
correspond to one of the tyre sizes and types designated for the
vehicle by the vehicle manufacturer. The minimum tread depth
shall be at least 80 per cent of the full tread depth.
Paragraph 3.1 of annex 3 “Methods of testing” was restructured and amended as follows:
3.1.
Measurement of the sound emission of the vehicle in motion
3.1.1.
Test arrangement and microphone positions
3.1.1.1.
The test arrangement is shown in figure 1.
Two lines, AA' and BB', parallel to the microphone line PP' and
situated respectively 10 m forward and 10 m rearward of that line
shall be marked out on the test track.
3.1.1.2.
The distance of the microphone positions from the line CC', on the
microphone line PP', perpendicular to the reference line CC' on the
test track (see Figure 1), shall be 7.5 ± 0.05 m.
81
The microphones shall be located 1.2 ± 0.02 m above the ground
level. The reference direction for free-field conditions (see IEC
61672-1:2002) shall be horizontal and directed perpendicularly
towards the path of the vehicle line CC'.
Two lines, AA' and BB', parallel to the microphone line PP' and
situated respectively 10 m forward and 10 m rearward of that line
shall be marked out on the test track.
The last sentence was originally under 3.1.1.3 and was merged with 3.1.1.2
Figure 1: Measuring positions for vehicles in motion
Figure 1 was moved from appendix 1 to this place in 3.1.1
3.1.2
Acceleration test execution, approach vehicle speed and gear use
3.1.2.1.
The vehicle shall approach line AA' at an initial steady vehicle
speed as specified below. When the front of the vehicle reaches
line AA' the accelerator handle shall be fully opened as quickly as
practically possible and kept in that position until the rear of the
vehicle reaches line BB'; the accelerator handle shall then be
returned as quickly as possible to the idle position.
For all measurements, the vehicle shall be driven in a straight line
along the test track in such a way that the track of the median
longitudinal plane of the vehicle is as close as possible to the
line CC'.
3.1.2.2
Approach vehicle speed
The vehicle shall approach the line AA' at a steady speed equal to
its maximum vehicle speed as defined in paragraph 2.8 of this
Regulation, if the latter is below or equal to 30 km/h. If the
maximum vehicle speed is above 30 km/h, the vehicle shall
approach AA’ at a steady speed of 30 km/h.
3.1.2.3
Gear use
If the vehicle is fitted with a manually-operated gearbox, the highest
gear shall be selected which enables it to pass over the line AA'
with an engine speed above or equal to 50 per cent of rated engine
speed as defined in paragraph 2.2.1.2 of this Regulation.
If the vehicle is fitted with automatic transmission, it shall be driven
at the vehicle speeds indicated in 3.1.2.2. above.
3.1.3
Sound level determination
The following amendments are proposed according to UN Regulation No. 41-04. In the
current text the individual measurement results are reduced by 1 dB and rounded to the
nearest integer and then the arithmetic average is calculated as the final result. The method
in UN Regulation No. 41-04 is more appropriate and this method is also used in 3.2 of annex
3.
The maximum sound level recorded at each side of the vehicle
shall be reduced by 1 dB(A) to account for measurement
inaccuracy and mathematically rounded to the nearest first decimal
place (e.g. XX.X). These values constitute the results of the
measurement.
The measurement will be invalid if an abnormal discrepancy is
recorded between the peak value and the general sound level.
At least two valid measurements shall be made on each side of the
vehicle.
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The measurements shall be considered valid if the difference
between the results of the two consecutive measurements on the
same side of the vehicle is not more than 2 dB(A).
Preliminary measurements may be made for adjustment purposes,
but shall be disregarded for the determination of the measurement
results.
3.1.4
Calculation of the final test result
The final test result is the average of the four test results rounded
off to the nearest whole decibel. If the figure following the decimal
point is between 0 and 4, the total is rounded down and if it is
between 5 and 9, it is rounded up.
Paragraph 3.2 of annex 3 “Measurement of sound emitted by stationary vehicles (conditions and
method of measurement for testing vehicles in service)” was amended as follows:




Figures 2 and 3 were moved from the appendices to the paragraph where they are
referenced.
½ was replaced by “50 per cent”.
¾ was replaced by “75 per cent”.
S was replaced by nrated with a reference to the definitions.
A new paragraph 4 was added in annex 3 in accordance with UN Regulation No. 41-04 as
follows:
4.
Sound from the vehicle in motion (data reported to facilitate in
motion testing of the vehicle in use).
4.1.
A test procedure for in-use compliance tests may be defined by a
Contracting Party, taking due account of any differences from the
test conditions used at type-approval.
4.2.
In order to facilitate in-use compliance test of vehicles, the following
information relating to the sound pressure level measurements
carried out in accordance with paragraph 3.1 of Annex 3 for the
vehicle in motion is referred to as in-use compliance reference
data:
4.3.
(a)
Gear (i) or, for vehicles tested with non-locked gear ratios,
the position of the gear selector chosen for the test;
(b)
The vehicle speed vAA’ in km/h at the beginning of the
maximum speed or full throttle acceleration test in gear (i);
and
(c)
The final test result in dB(A) as determined according to
paragraph 3.1 of this annex.
The in-use compliance reference data shall be entered in the
communication form conforming to annex 1.
The old paragraph 4 of annex 3 was deleted. To paragraph 5, the following amendments were
introduced:


“Engine speed s” was replaced by “rated engine speed as defined in paragraph 2.7 of this
regulation”.
Figure 4 was integrated in the paragraph.
Paragraphs 5.2.2 and 5.2.3 were added:
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5.2.2
All original silencers shall bear at least the following:
(a)
the ‘E’ mark followed by the reference to the country which
granted the type-approval;
(b)
the vehicle manufacturer’s name or trademark; and
(c)
the make and identifying part number.
This reference shall be legible, indelible and visible in the position
at which it is to be fitted.
5.2.3
Any packaging of original replacements for exhaust or silencing
systems shall be marked legibly with the words "original part" and
the make and type reference integrated together with the "E" mark
and also the reference of the country of origin.
3.2.7 Annex 4
Annex 4 was amended as follows:
“Category of mopeds” was replaced by “maximum design speed in km/h”.
3.2.8 Annex 5
Annex 5 remained unchanged, because it will be replaced by a reference to ISO 10844:2014 in
future.
The footnote "The specifications for the test site reproduced in this annex are valid until the end of
the period indicated in paragraph 10.8. of this Regulation" was added, in line with paragraph 2 of
Annex 3.
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3.3 Regulation 92
The final version of the amendment proposal for this regulation is annexed to this report.
3.3.1 Editorial amendments
The title was changed from “Uniform provisions concerning the approval of non-original
replacement exhaust silencing systems (RESS) for motorcycles, mopeds and three-wheeled
vehicles” to “Uniform provisions concerning the approval of non-original replacement exhaust
silencing systems (NORESS) for vehicles of categories L1, L2, L3, L4 and L5 with regard to sound
emission”.
The acronym “RESS” was replaced by “NORESS”, because the informal group on vehicle
propulsion system definitions (VPSD) decided to use “RESS” for rechargeable energy storage
systems and this was adopted by GRPE. Consequently, RESS was replaced by NORESS
throughout the whole regulation.
The wording “motorcycles, mopeds or three-wheeled vehicles” was replaced by “vehicles of the
categories L1, L2, L3, L4 or L5”. The word “motorcycle” was replaced by “vehicle”.
The word “noise” was replaced by “sound” or “sound emission” in order to bring it in line with UN
Regulation No. 41-04.
Whenever the word “speed” is used throughout the regulation, it is specified whether it is engine
speed or vehicle speed.
3.3.2 Amendments in paragraph 2, Definitions
In paragraph 2.6 (b) “Number and ratio of gears” was replaced by “Drive train, in particular the
number and ratios of the gears of the transmission and the final ratio”.
Paragraph 2.7 was added: "Rated engine speed" means the engine speed at which the engine
develops its rated maximum net power as stated by the manufacturer.
The symbol nrated, denotes the numerical value of the rated engine speed expressed in revolutions
per minute.
3.3.3 Amendments in paragraph 3, Application for approval
“Motorcycle” was replaced by “vehicle”.
Paragraph 3.3 (c) was modified as follows:
(c)
A test motor cycle vehicle representative of the type to which the
RESS NORESS is to be fitted. This motor cycle vehicle, when
measured for noise sound emission according to the methods
described in Annex 3 (including all relevant amendments) to
Regulation No. 9, Regulation No. 41 or Regulation No. 63 shall
satisfy the following conditions:
(i)
If the motorcycle, moped or three-wheeled vehicle is of a
type for which approval has been issued pursuant to the
requirements of each of Regulations Nos. 9, 41 or 63:
a. The sound level, during the test in motion shall not
exceed the specified limit specified in the appropriate
Regulation by more than 1 dB(A);
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b. The sound level during the stationary test shall not
exceed by more than 3 dB(A), the level determined
during the approval and indicated on the manufacturer's
plate.
(ii)
If the motorcycle, moped or three-wheeled vehicle is not of
the type for which approval has been issued pursuant to
the requirements of the appropriate Regulation, the sound
level shall not exceed by more than 1 dB(A) the limit
applicable at the time when it was first put on the road.
3.3.4 Amendments in paragraph 6, Specifications
Text in bold replace crossed out text or was added.
6.2.
Specifications regarding sound levels
The acoustic efficiency of the RESS NORESS or components
thereof shall be verified by means of the methods described in
Regulation Nos. 9, 41 or 63. This includes the requirements of
paragraph 6.3 of these regulations.
In particular, for the application of this paragraph reference shall
be made to the series of amendments to Regulation No. 92 which
was in force at the time of type approval of the new vehicle. When
the RESS NORESS or its components is fitted to the motorcycle,
moped or three-wheeled vehicle described in paragraph 3.3. (c),
the sound level values obtained using the two methods
(stationary and running vehicle in motion) shall satisfy the
following condition:
They shall not exceed the values measured in conformity with the
requirements of paragraph 3.3.(c), for the same moped,
motorcycle, or three-wheeled vehicle when fitted with the original
silencing system during either the running test of the vehicle in
motion, or the stationary test and additional tests, if required
in. paragraph 6.3 of Regulation Nos. 9, 41 or 63.
The following paragraph was added and after paragraph 6.2 and the existing
paragraphs 6.3 to 6.5 were renumbered accordingly.
6.3.
Additional requirements
6.3.1.
Tampering protection provisions
The NORESS or its components shall be constructed in
a way that does not permit removal of baffles, exit-cones
and other parts whose primary function is as part of
the
silencing/expansion
chambers.
Where
incorporation of such a part is unavoidable, its
method of attachment shall be such that removal is
not facilitated (e.g. with conventional threaded
fixings) and shall also be attached such that removal
causes permanent / irrecoverable damage to the
assembly.
6.3.2.
Multi-mode NORESS
NORESS with multiple, manually or electronically
adjustable, rider selectable operating modes shall meet
all requirements in all operating modes. The reported
sound levels shall be those resulting from the mode
with the highest sound levels.
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6.3.3
Prohibition of defeat devices
The NORESS manufacturer shall not intentionally alter,
adjust or introduce any device or procedure solely for
the purpose of fulfilling the sound emission
requirements of this Regulation, which will not be
operational during typical on-road operation.
6.3.4
Additional sound emission provisions
The requirements of paragraph 6.3 of Regulation No. 4104 shall also be fulfilled for the NORESS, if it is designed
to be used on vehicles that are type approved according
to Regulation No. 41-04 and are subject to the
requirements of paragraph 6.3 of Regulation No. 41-04.
If tests are to be performed, the vehicle as described in
paragraph 3.3. (c) shall be used.
The approval authority may require any relevant test
to verify the compliance of the NORESS to these
requirements.
The manufacturer shall provide a statement in
conformity with annex 4 of this Regulation, that the
NORESS or components to be approved comply with
the additional sound emission provision requirements
of paragraph 6.3 of Regulation No. 41-04.
3.3.5 Annex 1
In the existing annex 1 the following header was added:
“Part A NORESS for vehicle types approved according to the 04 series of amendments to
Regulation No. 41”.
Point 20 was deleted in order to bring annex 1 in line with the corresponding annex in UN Regulation
No. 41-04. The following points were renumbered accordingly.
A second Communication form was added with the header:
“Part B NORESS for vehicle types approved according to Regulation No. 9 or Regulation No. 63”.
Justification: The existing annex 1 is exclusively related to NORESS for vehicles type approved
according to UN Regulation No. 41-04.
3.3.6 Amendments in Annex 3
In annex 3, Requirements for fibrous absorbent materials used in RESS NORESS, paragraph 4
was amended as follows and the appendix was deleted:
4.
Before the system is tested in accordance with paragraph 6.2. of this
Regulation it shall be put into a normal state for road use by one of the
following conditioning methods in accordance with and as described in
paragraph 5.1.4. of Annex 3 of Regulations Nos. 9 or 63 or in paragraph
1.3. of Annex 5 of Regulation No. 41, whatever is applicable.
3.3.7 Annex 4, Statement of Compliance with the Additional Sound
Emission Provisions
A new annex 4 was added for NORESS that have to fulfil the requirements of the new paragraph
6.3.4 of this Regulation in order to align the ASEP requirements with UN Regulation No. 41-04.
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3.4 Further amendments proposed for Regulations 9
and 63, not yet adopted by GRB
3.4.1 Amendments for UN Regulation 63, presented at 64th GRB in
September 2016, kept on the agenda for further consideration at
future meetings
In addition to the working documents containing the amendments described above, an informal
document (GRB-64-11) was prepared and presented at the 64th GRB dedicated to add powered
cycles as a sub-category in UN Regulation No. 63 in order to align that UN Regulation with the
Regulation (EU) No. 168/2013 in full correspondence of vehicle categories.
This amendment would require modifications in the scope which can only be done when the vehicle
classification in the UN Consolidated Resolution on the Construction of Vehicles (R.E.3) would be
amended accordingly. Therefore, an informal document (GRB-64-18) with these amendments in
R.E.3 was prepared in addition to the informal document GRB-64-11 and sent to the UNECE
secretariat.
Both informal documents were discussed in the 64th GRB but kept on the agenda for further
consideration at future meetings. Since the amendments are only of importance for powered cycles
with a propulsion source other than an electric motor, which are only produced out of Europe and
their probable circulation in EU is very limited, the significance of these amendments, further than
the full formal alignment of UN Regulation No. 63 with Regulation (EU) No. 168/2013, needs to be
clarified.
3.4.2 Points related to L-category vehicles proposed for future work of
GRB
The following items, proposed for future work in GRB, are based on the results of this study, which
concluded the amendments proposals for UN Regulations Nos. 9, 63 and 92, submitted as official
documents to the 64th GRB. These items of future work were submitted to GRB as the informal
document GRB-64-17 and discussed at the 64th GRB; they were taken on board by the GRB for
further consideration at future meetings and in future informal meetings between the EC and IMMA,
ACEM and other involved organisations.
1. ASEP
With reference to the discussions between the EC and IMMA/ACEM on the current amendment
proposals for UN Regulations Nos. 9, 63 and 92, it was agreed that ASEP requirements for UN
Regulation No. 9 should not be included in those amendments for the time being. Such an
amendment would need much more data and preparation time than nowadays available for the
current amendments to UN Regulation No. 9 adopted in the 64th GRB. It was further agreed that
this issue should be added to the open issues list for future work in GRB.
In this context it is proposed to add ASEP requirements in UN Regulation No. 9 for those vehicles,
whose power to mass ratio exceeds 50 W/kg, in correspondence to UN Regulation No. 41-04.
Justification: As for L3 category vehicles, the operating conditions in real traffic for these vehicles
(mainly L5 category tricycles and trikes) cover a much broader range than that covered by the driving
conditions in annex 3 of UN Regulation No. 9. Consequently, ASEP requirements should ensure
that the sound emission of these vehicles at operating conditions not covered by the annex 3 tests
is coherent with the annex 3 test results.
Furthermore, the EC considers that an assessment about ASEP would not only be restricted to this
power to mass ratio class, but would also include the power to mass ratio class between 25 and 50
W/kg in both UN Regulation No. 9 and UN Regulation No. 41-04. Such requirements proposal is to
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be considered in line with UN Regulation No. 51-03, which contains ASEP requirements and these
are not restricted to vehicles, whose power to mass ratio exceeds 50 W/kg.
Regarding vehicles with power to mass ratios ≤ 25 W/kg: It is noted that L3 vehicles do not exist in
this power to mass ratio segment in the EU market. There might be some vehicles other than L3 in
this power to mass ratio segment, especially those for commercial use (transportation of goods),
but ASEP requirements would not be necessary for those vehicles due to their limited use compared
to the rest of L-category vehicles in this power to mass ratio interval.
2. Hybrid Electric Vehicles (HEVs) to be included in UN Regulation No. 9 and UN
Regulation No. 41-04
With reference to the discussions between the EC and IMMA/ACEM on the current amendment
proposals for UN Regulations Nos. 9, 63 and 92, it was agreed to incorporate HEVs in the UN
Regulation No. 9, mentioning the engine capacity and not the power to mass ratio, until ISO has
finalised its current work on system power specifications for L-category HEVs.
This was accepted, but it should be ensured that the ISO work will be made transparent and will be
accepted by GRB. Consequently, a future work subject was proposed to GRB for the
implementation of HEVs in UN Regulation No. 41-04 and a corresponding amendment of the
requirements for HEVs in UN Regulation No. 9 as soon as ISO has finalised its work.
Justification: Hybrid electric vehicles are included in the current amendment proposal of the EC for
UN Regulation No. 9, because the current measurement method does not require any system
power specification. Hybrid electric vehicles should also be included in UN Regulation No. 41-04.
This would require a system power specification, because the subcategories in UN Regulation No.
41-04 are based on power to mass ratio. This would also be required for UN Regulation No. 9, if
ASEP requirements would be added.
3. Revision of the measurement methods for L5 category vehicles
L5 category vehicles are vehicles with three wheels symmetrically arranged in relation to the
longitudinal median plane with an engine cylinder capacity in the case of a thermic engine
exceeding 50 cm3 or, whatever the means of propulsion, a maximum design speed exceeding 50
km/h.
They can be designed for the carriage of goods as well as for the carriage of passengers. In annex
I of the Regulation (EU) No 168/2013 they are sub-categorised as L5e-A (designed for the carriage
of passengers) and L5e-B (designed for the carriage of goods).
For L5 category vehicles designed for the carriage of passengers (also called tricycles and trikes),
the same measurement method as for L3 category vehicles (UN Regulation No. 41-04) should be
applied and the same subcategories based on power to mass ratio should be used.
It was proposed as a future work subject in GRB, to start as soon as possible. A concrete proposal
could be elaborated as soon as comments from stakeholders have been collected and considered.
Justification: Tricycles and trikes designed for the carriage of passengers have similar operation
conditions in real traffic as L3 category vehicles and thus should be measured accordingly.
3.5 General comments and recommendations
3.5.1 Electrified vehicles
For L1e category vehicles no requirements for electrified vehicles were added, because pure
electric L1e vehicles are exempted from sound emission requirements in the EU legislation and it
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is not estimated, that hybrid electric L1e vehicles will come easily into the market for cost and size
reasons.
3.5.2 In use compliance tests of vehicles in motion
With regard to in use compliance tests of vehicles in motion, it is well known from former research
studies that stationary tests are not very effective, because there is not enough load on the engine
and silencers can be constructed such as to deliver sound levels that comply with stationary tests
but lead to excessive sound emissions for full load acceleration tests.
This was already confirmed 20 years ago within a research project funded by the German Federal
Environment Agency (Steven, 2006a). In that project, 7 motorcycles were tested with their original
exhaust silencers and 13 non-original exhaust silencers; 2 of them had two operation modes and 6
others were further modified in order to increase the sound emission.
The abstract of this report is given below:
“Compared to other road vehicle categories the contribution of motorcycles to the overall noise
exposure is quite small. In contrast to that, their contribution to the annoyance is extraordinary high.
One reason is driving with high engine speed, which can be found more often for motorcycles than
for other vehicle categories, that causes extreme noise emissions. The second reason is the
frequent use of replacement silencers whose noise emission is much higher than that of the original
equipment. The main objective of this project was the creation of a noise emission database that
can be used for further discussions and political activities up to EU level.
The noise measurements should not only consider the current type approval measurement method
(as described in ECE R41) and the stationary noise test but also cover the method currently under
discussion for an amendment of ECE R41 (as described in ISO 362-2) and candidate methods that
can be used for an off-cycle emission provision concept. In this context off-cycle emissions are
noise emissions of driving conditions that occur in real traffic, but are not covered by the type
approval tests.
For the stationary noise test the differences between original silencers and replacement silencers
range from ‘nearly no difference’ to 11 dB(A). For the pass-by tests with wide open throttle according
to ECE R41 the differences are more evident. One replacement silencer was after an easy to do
‘illegal’ manipulation 23 dB(A) louder than the original silencer. Only few replacement silencers
would be detected as illegal by a roadside enforcement test according to ISO 5130.
This study proves the necessity for an amendment of the type approval method according to annex
3 of ECE R41 based on the ISO 362, part 2. Necessary is both, a regulation for the noise emissions
of acceleration phases on the outskirts and a regulation for a roadside enforcement test using
an easy to perform pass-by test.”
For explanation: The UN Regulation No. 41 at that time was 41-03, the mentioned ISO 362-2
standard equals UN Regulation No. 41-04. The ISO 5130 standard is equivalent to the stationary
test in UN Regulation No. 41-03. The results of this project were used for the development of the
roadside enforcement test and the amendment of UN Regulation No. 41 which resulted in UN
Regulation No. 41-04.
It is therefore recommended to perform in use compliance tests of vehicles in motion according to
annex 3, paragraph 3.1 of UN Regulations Nos. 9 and 63 and use the data specified in the added
paragraph 4 of annex 3 for the execution of such tests and for the compliance check.
The idea of a mobile test bench for in use compliance tests of vehicles in motion has the advantage
that sound emission tests could be combined with maximum speed tests for speed limited vehicles,
but there are several issues such as road load settings and background noise suppression, that
need to be resolved and validated, before such a measure could be applied at the roadside. And
this cannot be done on a short time base.
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3.5.3 Additional sound emission provisions (ASEP)
The EC required that additional sound emission provisions should be added to UN Regulations
Nos. 9 and 63.
It is proposed to require ASEP only for vehicles in UN Regulation No. 9, through an amendment to
it that will result from future GRB work, that are not dedicated to the transportation of goods with a
power to mass ratio exceeding 50 W/kg and to assess the necessity of ASEP for vehicles with
power to mass ratios between 25 W/kg and 50 W/kg. This affects some sub-categories of categories
L5 and probably L7.
For L1 and L2 vehicles such requirements are not necessary, because the annex 3 tests cover the
driving conditions in real traffic sufficiently. This was confirmed by other GRB experts. In this
context, and by considering that L2 category vehicles are technically much closer to L1 category
vehicles than to the other vehicle categories under the scope of UN Regulation No. 9, it is
recommended to delete L2 category vehicles from the scope of UN Regulation No. 9 and add them
to the scope of UN Regulation No. 63. In order to avoid misunderstandings, this proposal in not
meant to be included in the current amendment proposals for UN Regulations Nos. 9 and 63. But
it should be considered for future amendments.
For L5 and L7 category vehicles it is not an easy task to propose ASEP on a short time base. One
should remember that a lot of measurements dedicated to ASEP were performed and analysed in
an iterative process for the development of the provisions in UN Regulation No. 41-04.
One could take over the approach from UN Regulation No. 41-04, but the measurement results of
annex 3 are not compatible for UN Regulations Nos. 9 and 41-04, because driving conditions and
gear use are completely different. UN Regulation No. 9 still uses the methods of the previous
version of UN Regulation No. 41. Furthermore, UN Regulation No. 41-04 uses a sound pressure
level at wide open throttle limit curve as threshold for ASEP tests, which is related to the engine
speed when the vehicle crosses the line between the two microphones (PP’). It is impossible to
transform this curve to a UN Regulation No. 9 compliant system.
Therefore, further testing and analysis work is necessary in order to propose profound ASEP
requirements.
3.5.4 Defeat device tests
From former research projects it is known that manipulations of the acceleration at full load at the
driving condition(s) for the sound measurements (annex 3 of proposed amendments to UN
Regulation Nos 9 and 63) can be used as defeat device. This can easily be detected by full load
acceleration tests at entry speeds vAA’ below and above the vAA’ value, that is required in the above
mentioned annex 3 (e.g. vAA’ of annex 3 ± 5 km/h). If the average acceleration between AA’ and BB’
is significantly lower at vAA’ of that annex 3 compared to the lower and higher entry speed, the defeat
device hypothesis is well founded.
This proposal is not incorporated in the current amendments. It is meant as an example and should
be considered in further discussions for future amendments.
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4
Cost-Benefit Analysis of additional
measures
4.1 Context and approach
This chapter provides a cost-benefit analysis (CBA) of a more thorough noise control regulatory
framework for the noise emission of L-category vehicles. The objective is to perform a cost-benefit
calculation taking into account environmental benefits in moving to a more thorough noise control
regulatory framework and additional costs this entails to the industry, the suppliers and the
enforcement authorities.
The cost-benefit analysis requires a specific methodology and input data, tailored for the case of Lcategory vehicles, taking into account results of the technical assessment conducted in the
framework of the project, the stakeholder survey and other information from authorities, industry
and internet resources, such as:
 fleet numbers and composition including proportion of electric and hybrid vehicles,
 typical sound emission levels of L-category vehicles, place and time of occurrence,
 causes of excessive noise levels,
 levels of disturbance/annoyance,
 geographical differences,
 vehicle lifetime,
 size of after sales market,
 levels of tampering and in use compliance,
 levels and costs of enforcement,
 geographical differences,
 valuation rates for noise reduction in relation to amenity and health,
 additional costs of R&D, manufacturing and compliance testing,
 costs to retailers.
Some of this data differs per geographical area, which is taken into account to obtain a
representative picture for the EU as a whole.
The benefits include environmental and health benefits due to noise reduction. The costs include
additional costs for industry, the retail sector and enforcement authorities. The benefits, costs and
the benefit/cost ratio are determined over an appraisal period of 20 years.
The reduction in noise exposure from L-category vehicles is estimated with a straightforward model
for average LDEN and LNight noise levels at the façade due to multiple pass-bys of different types of
vehicles for different road types. Each of these road types are assigned typical population densities
of people living directly along the road.
The monetised environmental and health benefits are derived from the reduced noise exposure in
terms of the LDEN, numbers of exposed people and valuation figures. These figures are based on
those for willingness to pay (EU position paper, 2003) and more recent ones for health, primarily
based on the effects of stress-related myocardial disease and similar to those applied in the UK.
Costs are estimated based on additional costs for industry, retailers and authorities, such as
additional R&D, manufacturing and testing costs, sales volume changes and changed enforcement.
Only the most substantial costs are included.
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It should be noted that in general, due to the very nature of the models and input data, this type of
cost benefit analysis is indicative even though it is quantified. Fine tuning of the input data would
be possible if more detailed data on noise levels and numbers of excessively noisy vehicles were
available. This is probably because this type of data is not systematically evaluated. In addition, for
L-category vehicles, the vehicle flow is generally much lower compared to other traffic, although
often with significantly higher noise levels for a smaller number of the vehicles.
The approach followed can be summarized in the following steps:
 In section 4.2, the applied methodology for the CBA is described.
 In section 4.3 the input data used for the analysis is set out.
 The analysis itself and the results are presented in section 4.4
 Conclusions are given in section 4.5

4.2 Methodology for the CBA
4.2.1 Scope and general approach
The main effect to be considered in this analysis is improved legislation to such an extent that
excessive noise of L-category vehicles due to tampering, cycle beating and excessive driving
behaviour is effectively eliminated. The regulations in question are UN Regulation No 9 for tricycles
and quadricycles, No 63 for two-wheeled mopeds and No. 92 for motorcycle replacement silencers.
Three scenarios are considered for the improved regulations:
1. No change in excessive L-category vehicle noise despite the improved regulations.
2. Elimination of 50% of excessive noise from L-category vehicles.
3. Elimination of all excessive noise from L-category vehicles.
The vehicle types considered are in principle all L-category vehicle types covered by the UN
Regulations Nos. 9, 63 and 92, but the most relevant groups for environmental impact are mopeds
and motorcycles due to their large numbers compared to tricycles and quadricycles. Although UN
Regulation No. 41 for motorcycles is not in the scope of this study, motorcycles are affected due to
the regulation on replacement silencers and are therefore included in the CBA.
The geographical region considered is the EU28. Regional differences can be found in numbers
and usage of L-vehicles, in particular between the Mediterranean countries with much higher
numbers, and the rest of Europe. The timescale of regulations taking effect is 2016-2036.
In terms of environmental impact, methodologies of previous studies are followed as far as possible,
such as the Venoliva study (de Roo, 2011) on vehicle noise limits and a TNO study (Dittrich, 2015)
on effects of changing noise limits for road vehicles and tyres. These studies all use the LDEN
indicator to assess noise impact at the dwelling façade and to subsequently estimate numbers of
annoyed people using dose-effect relationships. The LDEN indicator is defined in the Environmental
Noise Directive 2002/49/EC (also known as the END) and is used as a measure for traffic noise
near dwellings. It is an equivalent sound pressure level weighted for the day, evening and night
periods.
The main difference with previous studies is that the sound emission from L-category vehicles often
has a limited contribution to average traffic noise levels, but part of the fleet which is non-compliant
or shows excessive driving behaviour contributes significantly to public annoyance and disturbance.
This is most pronounced in particular regions, seasons and road routes. The LDEN noise level is not
an ideal indicator for annoyance from L-category vehicles that produce higher single event levels,
but it is used here as the best available option as it allows to quantify overall noise reductions and
93
their corresponding monetisation. No standard approach is yet available for single event noise from
extra noisy vehicles, for dose-effect and monetisation relationships.
Noise reductions at dwelling facades in terms of the LDEN can be monetised based on a valuation
rate for annoyance per dwelling per dB noise reduction per annum (EU, 2003). Also for health
effects a similar type of valuation rate can be used. Although valuation provides a way to monetise
noise reduction benefits, uncertainties in the inputs mean that the results are indicative.
The benefit-to-cost ratio is derived from the accumulated discounted benefits and costs over the
appraisal period 2016-2036. The principles and value of discounting is applied in accordance with
EU guidelines (EC, 2015).
A schematic diagram of the CBA methodology is given in Figure 23 for the benefits from noise
reduction. The benefits are valued in terms of 'Willingness to pay' or 'Hedonic pricing' (property
valuation), and health benefits in terms of reduced occurrence if myocardial heart disease. The
valuation is given as Euro per dB noise reduction per dwelling per annum.
The main extra costs are considered to be the following:
 Sales loss of sports/replacement exhausts for retailers and manufacturers: these depend
on the average sales price of a replacement exhaust and numbers sold annually.
 Costs for additional R&D and production related to improving design to impede tampering,
cycle beating and excessive noise due to driving behaviour. As these costs are integrated
in the existing R&D budgets they are deemed to be limited due to the fact that many of the
solutions are already known and can be implemented without fundamental new
developments. R&D budgets in the automotive industry are known to be around 5% of
annual turnover in the EU.
 Costs for additional testing, mainly the ASEP, which are larger for motorcycles than for
mopeds. These affect mainly the manufacturers unless the cost is passed on to the
customer. The total sum of these extra costs is however limited as it only occurs for new
types put onto the market and is spread out over the whole production series. These costs
depend on the number of new vehicle types approved each year and the extra time and
facilities required for the test. The testing agencies may be unaffected as they are
contracted by the manufacturers or importers.
 Costs for Member States and enforcement agencies need not necessarily increase as the
regulation should reduce the numbers of illegal vehicles. Only if enforcement is increased
from a very low level to a more effective level, higher costs may occur.
94
Figure 23: Schematic diagram for monetised benefits of noise reduction of L-cat vehicles.
The costs for industry and authority stakeholders are illustrated in Figure 24.
95
Figure 24: Schematic diagram for CBA analysis, costs for noise reduction of L-cat vehicles.
4.2.2 Relevant findings from the stakeholders’ survey
The public consultation process, as conducted in the framework of the project, provided several
findings relevant for the cost-benefit analysis:
1. Noise perceived from L-category vehicles is considered to still be a significant problem for many
European citizens. Complaints about noise from these vehicles are quite frequent and the
problem is most intense in urban areas during all periods of the year; rural areas are also
affected especially during weekends and holiday periods by touring groups of motorcyclists.
2. Noisy L-category vehicles are characterized as ‘disturbing’ or ‘rather disturbing’ by almost all
participants of the survey; furthermore, half of the participants consider the noisy vehicles even
as a threat, because the noise distracts their attention when cycling or walking.
3. Most of the perceived noise is considered to come from tampered vehicles and especially
motorcycles; however, mopeds and other L-category vehicles are also considered to contribute
to the noise problem. The main noise responsible are considered to be drivers that tune or
modify the exhaust system or use special silencers (e.g. young drivers who enjoy producing as
much noise as possible, especially when driving at night).
4. The problem with the existing regulations lies mainly in their weak enforcement and the
insufficiently effective stationary inspection test. There is also potential for industry to design
around requirements and apply cycle beating technology. The main issue is that non-original
silencers are easy to fit which alter the vehicle noise levels.
5. More than half of the drivers who responded to the survey stated that their vehicle needs to be
quieter. An approximate 23% of L-vehicle owners are estimated to actually replace the silencer.
The main reason for doing so is for improved noise, better looks, more power, or other reasons
(increased noise, less weight, less cost, unavailability of original silencer e.g. after an accident).
6. A percentage as high as 80% of the survey respondents would like to see more done towards
noise control by:
96
 More anti-tampering measures, better market surveillance and enforcement of regulations
(e.g. by police control, roadside checks, more effective periodic technical inspection
checks);
 Improving noise tests to better reflect real driving conditions;
 Prohibition of defeat devices and of easy tampering by proper design measures;
 Impeding removal or modification of individual parts from an approved silencer.
 More strict noise limits in general to help reduce noise, although this is not sufficient in itself,
if not combined with better enforcement in practice.
The proposed amendments to UN Regulations Nos. 9, 63 and 92 are aimed at improved level of
stringency with respect to type approval, market surveillance and enforcement requirements, as
follows:
 Improvement of in-service conformity tests.
 Inclusion of additional sound emission provisions (ASEP).
 Better exclusion of defeat devices.
 Reducing levels of tampering and non-compliant replacement parts.
Main premise of the CBA
Based on the above, the main premise of the CBA is that the improved legislation should
significantly reduce or eliminate excessive noise from L-category vehicles in the future, by reduced
tampering, improved test methods, exclusion of defeat devices and improved market surveillance
and enforcement.
4.2.3 Other resources and information
There are several other internet and literature resources which are of use in considering the
magnitude of the noise impact of L-cat vehicles.
In the Netherlands, the 'Atlas Leefomgeving' (web-based Interactive Atlas of the Living
Environment) (Atlas, 2016) includes maps of noise annoyance from road vehicles including a
separate map for noise from mopeds, as these are considered one of the main sources of
annoyance and sleep disturbance. This shows average rates of annoyance (percentage of the
population) due to mopeds based on local surveys. These figures may actually include some noise
from motorcycles too, as the public may not necessarily distinguish the vehicle type. Large parts of
the country are found to have serious annoyance rates of 5-10% and 10-20% in some urban areas.
From various articles it is known that motorcycle touring is a source of severe annoyance in some
rural areas, for example along winding country dike roads in the Netherlands (NRC, 2015;
Waterman, 2014), and scenic routes in the alps (Lercher, 2009). Although the noise impact is mainly
at weekends, holidays and during good weather conditions, noise levels can be unbearable for
people living along such routes, affecting their quality of life significantly.
In the scope of this study, information has been provided by the German authorities (BMVI) on
enforcement of noise regulations. In Germany, L-vehicles may be stopped by police if the vehicle
is considered to be too noisy. This is followed up by a stationary or a pass-by noise test. If the
vehicle is above permitted noise levels, the cause is investigated, such as tampering (e.g.
dismantling the dB-killer), wear or corrosion, geometry changes, wrong exhaust or others. A fine
can be imposed, and if the vehicle does not comply with the regulation, the driver has to provide a
legal silencer and install it, otherwise the vehicle has to be transported by truck or trailer.
According to BMVI, two main effects are expected due to the changes in UN-R9, 63 and 92:
97
 The number of L-category vehicles assessed as “subjectively too noisy” will probably
decrease due to prohibition of dB-Killers and/or variable geometries;
 For police checks on L-category vehicles considered subjectively too noisy, the chance of
a fine will be higher, as the chance of 'legal noisy driving' will be smaller.
4.3 Input data
4.3.1 Environmental data
The main impact of improved regulation (and thereby easier enforcement) should be, in the best
case, elimination of noise disturbance due to noisy L-category vehicles. In effect this implies a large
noise reduction of the individual noise events which well exceed the average noise levels from other
traffic.
Vehicles included
For the environmental impact, only mopeds and motorcycles are considered due to their
predominance in numbers compared with quads and three-wheelers.
Regional differences in traffic composition
As the proportion of L-category vehicles is much larger in Mediterranean countries than for the rest
of Europe (Steven, 2006; Paviotti, 2012), Northern European countries and Southern
Mediterranean countries are analysed separately.
Fleet size
The fleet numbers of motorcycles in the EU28 are estimated for 2013 based on data from ACEM,
set out in Table 3. Current numbers of L-category vehicles in the EU28 are around 35 million, of
which 11 million (about one third) are mopeds and 24 million are motorcycles. About 55% of these
vehicles are used in Mediterranean countries (numbers in bold print in Table 3) although in terms
of population, these represent 40% of the total EU28 population of 508 million inhabitants in total.
Electric and hybrid vehicles
Numbers of electric and hybrid L-category vehicles are still relatively low in Europe, with annual
sales in the tens of thousands for the whole EU. According to Ewalds (2013) only 1 in 38 new
scooters were electric in 2012 in the Netherlands. According to Cleanrider (2014) the total number
of electric scooters sold outside the Asian-Pacific region in 2013 was 31,338 which is 8% of the
registrations in the EU if these were all to be attributed to the EU. In terms of EU fleet numbers,
they are estimated to be below 2% although some growth can be expected due to national and
local incentives.
Data on sales of electric and hybrid motorcycles was not found, but it would seem that their numbers
are relatively low as is the case for mopeds. In addition, electric vehicles are not subject to the
sound emission requirements and hybrid vehicles emit significantly less noise than combustion
engine powered ones. For this reason, electric and hybrid L-category vehicles are not included in
the analysis. The only reason to do so would be to adjust future total numbers of these.
98
Table 3: Fleet size data for mopeds and motorcycles in the EU28 countries. Data is unavailable for
the empty fields. Bold figures are for the Mediterranean countries including France and Portugal.
Red shaded figures are those above 1 million.
Growth of number of L-category vehicles
Numbers of L-category vehicles can be expected to grow in coming years by at least 1% annually
due to increasing urbanisation, traffic congestion and lack of parking space for cars, probably more
rapidly than numbers of cars. This growth is however not included in the analysis, as it has little
impact on the average traffic noise levels. The estimated number of cars in the EU28 is around 250
million, about seven times the number of L-category vehicles, which however produce higher noise
levels than cars.
Vehicle life, mileage and usage
Vehicle life of motorcycles and mopeds varies significantly depending on usage and maintenance.
Typical usage may be for commuting, professional use such as emergency services and couriers,
or for touring and recreation including rental.
Vehicle life of motorcycles varies significantly from about 6 to 18 years, taken here at an average
of 12 years. Mopeds have a shorter average life span of around 8 years. Mileage can vary hugely.
But average mileage based on overall vehicle fleet mileage in the Netherlands is for example
around 2.2 billion vehicle kilometres for 2014 for motorcycles and approximately the same for
mopeds (Compend, 2014). On average this corresponds to 4,200 km/year for motorcycles and
3,100 km/year for mopeds. ACEM gives an average annual mileage for PTWs of 5,000 km/year.
99
Sound emission levels of 2 wheelers
Typical sound emission levels of 2 wheelers under normal road conditions can be found in Paviotti,
(2012) and Steven (2004). Measured maximum sound pressure levels (LpAFmax) on Athens streets
of 83 dB(A) are found for motorcycles at 40-70 km/h and 81 dB(A) for mopeds at 7.5 m distance.
Statutory noise calculation methods such as EU-CNOSSOS, the Dutch SRM method and statistical
pass-by measurements, e.g. (Steven, 2004), show around 76 dB(A) for motorcycles and 78 dB(A)
for mopeds and at these speeds. This is a 3 dB difference for mopeds and a 7 dB difference for
motorcycles, which may be due to local fleet composition, driving behaviour, vehicle age and
exhaust condition and numbers of noisy exhausts (illegal, tampered or faulty).
In Figure 25, sound power levels of mopeds and motorcycles are set out for the EU-CNOSSOS
model, the Dutch SRM I and II models and German statistical roadside measurement data. The
CNOSSOS curves are actually used here, neglecting the rolling noise for the vehicles. The sound
emission is based on these curves, but also with a correction for illegal exhausts added and energy
weighted in proportion to the percentages of illegal and legal exhausts. A 10 or 15 dB increase is
applied for motorcycles and 7 or 10 dB is applied for mopeds (this might be higher in some cases,
considering that the road speed limit is often exceeded by vehicles with illegal exhausts).
Typical noise reductions
The potential reductions at source level are considered to be on average 5-10 dB in the maximum
sound pressure levels for illegal or faulty exhausts and 5 dB for driving behaviour or specific driving
conditions insufficiently covered by the test. These two increases are combined, to 10-15 dB
excessive noise for motorcycles and 7-10 dB excessive noise for mopeds. Potential noise
reductions are assumed from an average excessive level for L-category vehicles, down to known
typical noise levels of compliant vehicles in normal traffic.
Numbers of vehicles with illegal exhausts
According to ACEM, percentages of illegal exhausts are 63% for motorcycles and 35% for mopeds
(ACEM, 2004). The term 'illegal exhaust' refers in this case not only to replacement exhausts that
are not approved for use on the road, but also those that have been modified or simply adjusted by
means of baffles, valves, 'dB-killers' or control switches (even handlebar mounted or remote
controlled). Electronic 'Sound Management Systems' are available on the market.
According to the German authorities (BMVI) only 25% of PTWs are too noisy actually due to illegal
exhausts (or parts), the remainder of noisy vehicles is due to driving behaviour, variable geometries,
wear and ageing, and higher noise levels than the approval.
The figure of 25% is used in the CBA, but if a higher percentage were to be used, it would result in
even higher benefits and larger reductions in average traffic noise levels.
100
Motorcycles
LWA dB(A)
130
CNOSSOS
120
NL‐SRM II
110
NL‐SRM I
DE
100
90
80
70
0 10 20 30 40 50 60 70 80 90 100110120130140
Speed km/h
Mopeds
LWA dB(A)
130
CNOSSOS
120
NL‐SRM II
110
NL‐SRM I
DE
100
90
80
70
0 10 20 30 40 50 60 70 80 90 100110120130140
Speed km/h
Figure 25: Sound power levels for motorcycles (top) and mopeds (bottom) calculated according to
CNOSSOS-EU, the Dutch SRM I and II traffic noise models and German measured data (Steven). The
green/red curve is used in the analysis.
Road types considered
The road types included in the analysis are residential roads, main roads in urban areas, arterial
roads, motorways and roads in rural areas. Their lengths and inhabited lengths, together with typical
speeds and population densities are set out in Table 4. These are the same values as used in the
Venoliva study (Veno, 2011). Only those road stretches with dwellings along them are considered.
For the current study a further deduction of 50% has been made for roads where L-category
vehicles are frequent, and a split has been made between Northern (62% of roads) and Southern
Europe (38% of roads). For Northern Europe only 20% of the time is taken into account for
motorcycles, as these are deemed to cause the most noise exposure from L-category vehicles on
days in the touring season of motorcycles and in holiday periods with good weather. For Southern
Europe, mainly the Mediterranean countries, the environmental impact is considered throughout
the whole year.
101
Table 4: Road types, lengths and population densities in the EU28 as derived for the Venoliva study,
with estimates for inhabited road lengths, length with PTWs occurring (50%) and split into Northern
and Southern parts of the EU.
Typical speeds
EU28 totals
Inhabited
50% with PTWs
62% North EU
38% South EU
Exposed/km
Exposed North
Exposed South
km/h
Length, km
Length, km
Length, km
Length, km
Length, km
People/km
People
People
Residential Arterial Urban Rural Roads
Main Roads Roads
Motorways Motorways Rural Roads Totals
30‐50
30‐50
50‐70
70‐120
80‐130
50‐100
1660601
251606
100643
5032
95610
2918633
5032125
1079391
201285
90578
4026
47805
1459316
2882401
539696
100643
45289
2013
23903
729658
1441201
334611
62398
28079
1248
14820
452388
893544
205084
38244
17210
765
9083
277270
547656
250
500
500
1000
50
20 83652803
31199175
14039590
1248060
740978
9047759 139928364
51271073
19122075
8604910
764940
454148
5545401
85762546
Typical average traffic noise levels
Potential noise reductions at typical façade distances of dwellings along the road are estimated for
each selected road situation. These distances are either 15 m for residential, main and arterial
roads in urban areas, and 50 m for motorways and rural roads. In reality, L-vehicles with excessive
noise levels can often be heard over a long distance impacting other dwellings well beyond those
directly along the road.
Typical average traffic noise levels as LDEN and their change due to complete noise reduction of
excessively noisy L-category vehicles, for 10/7 dB reduction (motorcycles/mopeds), are shown in
Figure 26 for different road types for Southern Europe. The typical noise reduction is 1.1 dB in LDEN
and LNight noise levels.
For Northern Europe the traffic noise reductions are only 0.1 dB, even though on individual roads
and for individual vehicles at certain times, the noise emission goes down much more (7-10 dB).
The noise reductions at the façade in dB are used to determine the monetised benefits as set out
in the following section.
80
LDEN for Southern Europe, for excessively noisy PTWs
before and after effect of regulation change
LDEN dB(A)
75
70
65
60
55
Baseline
After change
50
Figure 26: Calculated LDEN levels for different road types, showing the reduction in traffic noise levels
as LDEN, for Southern Europe for scenario 3b.
102
4.3.2 Socio-Economic benefits
The benefits of reduction of road traffic noise in general are mostly expressed in terms of reduced
noise levels and annoyance and sleep disturbance, especially for long term exposure. Stress,
concentration loss and various health effects can be linked with these two parameters.
Annoyance is generally associated with the annual average LDEN level at the dwelling façade
(equivalent sound pressure level weighted for day-evening-night), whereas sleep disturbance is
associated with the night level Lnight.
For annoyance, the 2003 European position paper (EU, 2003) recommends a valuation figure
based on willingness to pay (e.g. the value people perceive) or Hedonic pricing (property value
change) of 25 Euro per dwelling per annum per dB noise reduction in 2002. This valuation is referred
to as 'amenity' from here on. Taking 1% inflation into account this figure is set at 28.74 Euro. The
real value is often much higher than this, in particular when the traffic noise level affects the sales
price of property.
The annual benefit for amenity (due to reduced annoyance) BA is calculated from
BA = VA * NH * NR
where VA = benefit per household per dB noise reduction for amenity
NH = number of households
NR = dB noise reduction of the average equivalent noise level at the façade.
Health benefits are based only on myocardial heart disease to avoid overlap with benefits of
reduced annoyance. Myocardial heart disease is considered in the literature to be the most
significant and clearest long term health impact. For sleep disturbance and health effects associated
with myocardial heart disease, a valuation figure of 16.75 Euro per dB reduction per household per
annum for 2015 is derived from UK figures (IGCB, 2010) adjusted for general application as in Zyl
(2012).
The annual health benefit valuation Bhealth per household and per dB noise reduction can be
calculated from
Bhealth = VAMI * NH * NR
where VAMI = health benefit per household per dB noise reduction, related only to Acute
Myocardial Infarction
NH = number of households
NR = dB noise reduction of the average equivalent noise level at the façade.
Where the benefits occur only for parts of the year, such as weekends and holidays, then the
valuation rate is adjusted proportionally by the percentage of the year during which the vehicles are
present.
4.3.3 Costs for affected stakeholders
Additional costs due to the amendments in regulations can be expected for manufacturers, the retail
sector and road enforcement and market surveillance authorities.
For the L-category vehicles industry, data from ACEM, the European Association of Motorcycle
Manufacturers, has been taken into consideration. ACEM represents 14 manufacturers producing
103
more than 30 brands, and 18 national associations from 15 European countries, employing over
125,000 people. The aggregated turnover of the PTW sector (manufacturing, plus upstream and
downstream activities) amounted to Euro 27 billion in 2011. Manufacturers alone account for Euro
5 billion. The members of ACEM account for 90% of the European powered two-wheeler production.
ACEM also represents main manufacturers of tricycles and quadricycles.
Information on after sales parts can easily be found on the internet, where a large variety of road
legal and non-road legal parts is available, including sports exhausts, variable exhausts and dBkillers.
For enforcement of noise regulations, roadside or patrol checks are performed by the police. These
may be road checks by enforcement teams with noise measurement equipment or by individual
officers who observe high noise levels subjectively, following up with a vehicle check.
In individual EU member states enforcement can be very differently organised and have different
levels of penalties and frequency of checks. Although these are sometimes avoided by the use of
dB-killers or by temporary refitting of the exhaust, it can be effective, as information on enforcement
activity and penalties is shared on internet forums. High fines can be imposed and in some cases
the vehicle is impounded or the owner is obliged for it to be reapproved. Cases for penalties may
include:
 driving with an exhaust not approved for road use;
 driving with the wrong exhaust (e.g. approved but not for vehicle in question);
 driving with a vehicle with tampered exhaust and/or speed limiter;
 driving with an approved, but damaged, worn or otherwise malfunctioning exhaust;
 speeding and/or excessively noisy driving with an approved or tampered vehicle;
 producing excessive noise due to switching off or removing the dB-killer, if present.
Market surveillance is performed by national or regional authorities such as customs and inspection
agencies and covers import and retail of vehicles and components.
The following cost estimates were made based on stakeholder information from ACEM and BMVI,
product pricing found on Internet and assessment by the study authors.
Costs for additional R&D are related to improving design to impede tampering, cycle beating and
excessive noise due to driving behaviour. This may be limited to general R&D as most solutions
will be applicable to a wide range of vehicle types. An average additional R&D budget of
 100,000 Euro per company per annum for motorcycles
 50,000 Euro per company per annum for mopeds
assuming 0.5 R&D man-years per company per annum at a rate of 200,000 Euro per annum. These
R&D costs will only be required over a limited period until the solutions are fully available, taken at
3 years. For 30 companies this would amount to a total of 3 million Euro, considering that solutions
can be developed jointly or shared.
Additional production costs related to improving design to impede tampering, cycle beating and
excessive noise due to driving behaviour. An average additional production cost of
 25 Euro per new moped,
 100 Euro per new motorcycle,
 5 Euro per new replacement silencer,
104
is assumed to cover this, approximately 0.5-1% of the price of a new vehicle or exhaust, mainly for
limited extra materials or devices taking into account the improvements in the regulations. After 5
years these extra costs should disappear once the technical solutions are fully integrated into the
vehicle design.
Costs for additional testing are considered mainly to be due to the ASEP, and higher for
motorcycles than for mopeds/replacement silencers. These affect mainly the manufacturers, unless
the cost is passed on to the customer. The total sum of these extra costs is however limited as it
only occurs for new types put onto the market and is spread out over the whole production series.
It includes additional human resources, instrumentation and training.
Additional test costs of
 150,000 Euro for each new motorcycle model,
 100,000 Euro for each new moped model,
 2,000 Euro for each new replacement silencer type,
are estimated by the authors due to ASEP over the whole appraisal period. If an average of 4 new
models per manufacturer is assumed for each year, estimate based on motorcycle review websites,
for 30 companies (ACEM) this amounts to 12 million Euro per annum.
If only the L5 category (tricycles) is considered as proposed by ACEM (‘complete overhaul for L5’),
these costs would be the fraction of the above amount of 12 million Euro corresponding to the
proportion of L5 vehicles, which according to ACEM was around 1.5% in 2015. This would be
around 180,000 Euro per annum for L5 vehicles.
The sales loss of sports and replacement exhausts (and inlets) for retailers and manufacturers
are considered here to depend on the average sales price of a replacement exhaust and numbers
sold annually. An average price of 400 Euro is assumed here for a motorcycle exhaust, for which
prices can vary from 200 to well over 1,000 Euro depending on the materials used. Some exhausts
are sold as 'Road Legal' but can easily be adjusted by valves, switches or baffles to produce more
noise. For mopeds the prices are lower, estimated at an average of 100 Euro.
The annual market for exhausts is considered to be proportional to the numbers of annual
registrations as indicated in Table 5 multiplied by the percentage of illegal exhausts. An illegal
replacement exhaust is one that does not comply with the regulation, or is not intended for road
usage. Legal exhausts may also be too loud due to ageing, damage, or tampering.
This number is reduced by half again as part of the replacement exhausts may not be adjusted.
Table 5: Sales value of replacement exhausts resulting in higher noise levels for 2-wheelers.
Only the sales of illegally used exhausts will be affected (25%).
Number of annual new
registrations in EU28, 2014
(ACEM)
Percentage
strictly illegal exhaust
Annual number of new vehicles
with illegal exhaust fitted
Average replacement exhaust
price
Percentage due to new noisy
replacement exhaust
Motorcycles
Mopeds
Total
798,328
340,468
1,138,796
25%
20%
-
199,582
68,094
267,676
400 Euro
100 Euro
50%
50%
105
Approximate sales value of
potentially noisy replacement
exhaust in the EU28
40 MEuro
3.4 MEuro
43.4 MEuro
Additional costs for enforcement and market surveillance
Costs for noise enforcement of L-category vehicles are difficult to estimate as they may vary
significantly between member states in terms of organisation, procedures and frequency.
Enforcement of noise regulations should include:
 excessively noisy driving including speeding, which can be covered by general enforcement
by patrol officers;
 vehicles exceeding the limits for roadside tests, either due to illegal, tampered or faulty
exhausts.
As the additional effort of enforcement will probably not change much and the new regulation may
actually improve its effectiveness, it could be argued whether or not actually to consider additional
enforcement costs. In any case an estimate is made, considering typical manpower requirements.
Enforcement costs can be estimated for a typical roadside testing team: 3 enforcement staff working
8 hours a day with an hourly rate of 100 Euro, amounting to 2,400 Euro a day. Takings in terms of
fines should then be deducted from this amount. If it is assumed that 10 fines of 100 Euro are levied,
then the total daily cost per team is 1,400 Euro. If one team is assumed to be active per area of 1
million people, for the whole EU28 the effective costs amount to 1,400 x 508 = 0.71 million Euros a
day, with the current EU 28 population at 508 million inhabitants.
An annual cost estimate can be based on a fixed number of days, for example one fifth of the year
(73 days), resulting in 73 x 0.71 million = 51 million Euro per annum.
If one team can test around 25 vehicles in one day, then in one year 0.3% of the whole EU fleet of
35 million vehicles could be tested with 50 teams during 73 days (20% of the year).
For market surveillance and enforcement, existing teams would mostly be tasked, ensuring that
illegal exhausts and components are taken off the market through retail channels. A difficulty here
is dealing with imports through the internet and non-compliant second-hand trading.
The costs for this are assumed to be far smaller than roadside enforcement and may to some extent
be covered by takings from fines.
4.4 Results
The cost-benefit-analysis derives the benefit-to-cost ratio based on the calculated benefits over the
appraisal period 2016-2036. The total socio-economic benefits consist of amenity and health
benefits. The costs are additional costs for the manufacturing industry, component retailers and
enforcement authorities. The CBA is considered for three scenarios, varying the percentage of
quieter vehicles and the noise reduction:
 Scenario 1, baseline: No effect on excessive noise, no changes in enforcement or parts
sales, 25% of L-category vehicles are assumed to produce more noise due to illegal
exhausts.
 Scenario 2: Half of all excessively noisy L-category vehicles (12.5% of total fleet) are
assumed quieter by
a) 15 dB for motorcycles and 10 dB for mopeds,
b) 10 dB for motorcycles and 7 dB for mopeds,
106
both with better enforcement and less sales of illegal exhausts;
 Scenario 3: All excessively noisy L-category vehicles (25% of total fleet) are quieter by
a) 15 dB for motorcycles and 10 dB for mopeds,
b) 10 dB for motorcycles and 7 dB for mopeds,
both with better enforcement and less sales of illegal exhausts.
Scenario 1 is the baseline situation, in which there are no benefits, but potentially only costs. Here,
it is assumed that enforcement costs and sales of illegal exhausts and parts do not change, but that
manufacturers bear additional costs for R&D, production and testing. In scenario 2 and 3 costs of
extra enforcement and losses due to reduced sales of illegal exhausts are included.
The amenity and health benefits per annum are detailed separately for the Northern European and
Southern European areas together with the costs for stakeholders in Table 6, for scenario 3b. The
costs include additional R&D, production and testing costs for industry, enforcement costs for
authorities and sales loss of illegal exhausts for retailers. The results are set out graphically in
Figure 27. The benefits are derived from the average reductions of equivalent noise levels for all
road types, estimated for scenario 3b at 0.1 dB reduction for Northern Europe and at 1.1 dB
reduction for Southern Europe. This difference is mainly due to the higher proportion of L-category
vehicles in Southern Europe compared to Northern Europe.
A standard discount rate of 4% is taken into account for the whole appraisal period, as suggested
in the EU guidelines (EC, 2015). The discount rate is applied to determine the present value of
future amounts, effectively lowering these with increasing years. The discounted value in year n Bdn
is calculated from the value B0 in the first year with n=0 and the discount rate r with
Bdn = B0 /(1+r)n
The costs are discounted in the same way.
A 1% interest rate is applied for the increase in valuation rates for amenity and health. So these
valuation rates both increase by 1 % annually.
The net present value NPV, which is the discounted value of benefits minus the discounted value
of costs as expressed in the formula below, can be set out annually, as shown in Figure 28.
Accumulated benefits for Northern and Southern Europe are combined.
NPV=
with Bi =benefits in year i, Ci = costs in year i, and r= discount rate.
107
0,008 141327580
0,016 142740856
0,025 144168264
0,033 145609947
0,041 147066046
0,049 148536707
0,057 150022074
0,065 151522295
0,074 153037517
0,082 154567893
0,090 156113572
0,098 157674707
0,098 159251454
0,098 160843969
0,098 162452409
0,098 164076933
0,098 165717702
0,098 167374879
0,098 169048628
0,098 170739114
0,098 172446505
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
dB
Exposed
Year reduction people
Northern Europe
22,3
22,8
23,2
23,6
24,1
24,6
25,1
25,5
26,0
26,6
24,8
23,0
21,1
19,1
17,1
14,9
12,7
10,3
7,9
5,4
2,7
13,3
13,5
13,8
14,1
14,3
14,6
14,9
15,2
15,5
15,8
14,8
13,7
12,5
11,4
10,1
8,9
7,5
6,1
4,7
3,2
1,6
Amenity Health
35,6
36,3
37,0
37,7
38,4
39,2
40,0
40,7
41,5
42,3
39,6
36,7
33,7
30,5
27,2
23,8
20,2
16,5
12,6
8,6
4,4
642,3
606,7
570,4
533,5
495,7
457,3
418,1
378,2
337,4
295,9
253,6
214,0
177,3
143,7
113,2
86,0
62,2
42,0
25,5
12,9
4,4
Total
Acc.
Benefits Benefits
Benefits including discounting
MEuro
90137252,9
92868501,8
1,121 105693017,9
1,121 104646552,3
1,121 103610447,9
1,121 102584601,8
1,121 101568912,7
1,121 100563279,9
1,121 99567603,87
1,121 98581786,01
1,121 97605728,72
1,121 96639335,37
1,027 95682510,27
0,934 94735158,68
0,840 93797186,81
0,747
0,654 91949011,68
0,560 91038625,42
0,467
0,374 89244804,85
0,280 88361192,92
0,187 87486329,62
0,093 86620128,34
dB
Exposed
reduction people
Southern Europe
781,9
797,2
812,7
828,6
844,8
861,2
878,0
895,2
912,6
930,4
869,5
805,9
739,5
670,1
597,8
522,4
443,8
362,0
276,8
188,1
95,9
464,9
474,0
483,2
492,7
502,3
512,1
522,1
532,3
542,6
553,2
517,0
479,2
439,7
398,4
355,4
310,6
263,9
215,2
164,6
111,9
57,0
Amenity Health
MEuro
1246,9
1271,2
1296,0
1321,3
1347,0
1373,3
1400,1
1427,4
1455,3
1483,7
1386,5
1285,1
1179,1
1068,6
953,2
833,0
707,7
577,2
441,4
300,0
152,9
22506,8
21260,0
19988,8
18692,8
17371,5
16024,5
14651,2
13251,1
11823,7
10368,4
8884,8
7498,2
6213,1
5034,0
3965,4
3012,2
2179,2
1471,5
894,2
452,9
152,9
Total
Acc.
Benefits Benefits
Benefits including discounting
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
2,0
2,2
2,3
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
0,0
28,7
59,6
93,0
129,0
94,0
0,0
0,0
0,0
0,0
0,1
0,1
0,2
0,4
0,7
1,1
1,8
2,6
3,7
5,1
6,7
8,5
10,3
12,0
13,5
14,7
15,2
0,0
0,0
0,1
0,1
0,2
0,5
0,8
1,4
2,4
3,8
5,9
8,7
12,4
17,0
22,4
28,3
34,5
40,3
45,3
49,0
51,0
0,0
0,0
0,1
0,1
0,2
0,4
0,7
1,2
2,0
3,3
5,0
7,4
10,6
14,5
19,0
24,1
0,0
0,1
0,1
0,3
0,5
1,0
1,8
3,1
5,1
8,2
12,7
18,8
26,7
36,6
48,1
60,9
29,3 102,7
34,3 146,3
38,6 192,5
41,7 236,5
43,4 205,9
1107,9
1107,9
1107,8
1107,7
1107,4
1106,9
1105,9
1104,1
1101,0
1095,9
1087,7
1075,0
1056,2
1029,5
992,9
944,8
883,9
781,2
634,9
442,5
205,9
Costs including discounting (Meuro)
Exhaust
Produc
Enforce sales
Total Acc.
R&D tion
Testing ment
loss
Costs Costs
EU28 Stakeholder costs
23149
21867
20559
19226
17867
16481
15068
13626
12156
10656
9126
7693
6364
5141
4030
3037
2139
1367
727
229
-49
NPV
Table 6: Discounted social-economic benefits and stakeholder costs for reduced noise from Lcategory vehicles in the EU28. 25% of the vehicles are assumed to produce excessive noise
assumed to be reduced by 10 dB for motorcycles and 7 dB for mopeds. Benefits are separated for
Northern and Southern Europe and are due to reduction in the traffic equivalent noise level due to
mopeds and motorcycles on all road types.
108
Benefits and costs
Million Euro
1800
1600
Amenity
1400
Health
1200
Total Benefits
1000
R&D
800
Production
600
Testing
Enforcement
400
Exhaust sales loss
200
Total Costs
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
0
Figure 27: Discounted social-economic benefits and stakeholder costs for reduced noise from Lcategory vehicles in the EU28, for scenario 3b. 25% of the vehicles are assumed to produce
excessive noise assumed to be reduced by 10 dB for motorcycles and 7 dB for mopeds. Benefits are
separated for Northern and Southern Europe and are due to reduction in the traffic equivalent noise
level due to mopeds and motorcycles on all road types.
Net present value
25000
Miullion Euro
20000
15000
10000
5000
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
0
Figure 28: Net Present Value (difference between accumulated benefits of Northern and Southern
Europe combined and accumulated costs) over the appraisal period for scenario 3b.
The total discounted benefits and costs and the benefit-to-cost ratio for the whole appraisal period
are set out in Table 7, including the results for scenarios 1, 2a/b and 3a/b. Clearly the benefits
outweigh the costs, which is mainly due to the large benefits for Mediterranean countries. For a
noise reduction of 10 dB for motorcycles and 7 dB for mopeds producing excessive noise, for half
of the vehicles, the benefit-to-cost ratio is 10, and for all the vehicles, 20. If the noise reduction is
109
actually higher, 15 dB for motorcycles and 10 dB for mopeds producing excessive noise, the benefit
to cost ratio is even higher, up to 47 in the extreme case.
Table 7: Total accumulated benefits and costs for both geographic areas combined in millions of
Euros, for scenarios 1, 2 and 3. Subscenarios a and b are for reduction levels of 15/10 dB and 10/7
dB for motorcycles and mopeds respectively.
110
4.5 Conclusions
A cost-benefit analysis has been performed to evaluate the benefit-to-cost ratio of the changes to
the UN Regulations Nos. 9, 63 and 92 for L-category vehicles. The benefits included amenity and
health benefits, the costs included those for vehicle manufacturers, replacement exhaust retailers
and enforcement authorities. The analysis was performed over an appraisal period of 20 years from
2016. Costs were estimated for the whole EU28, whereas benefits were determined separately for
Northern and Southern Europe, as the contribution of L-category vehicles in the traffic flow differs
between these areas.
Motorcycles and mopeds were included in the analysis as they are by far the most numerous, and
are both affected by the new regulations. Separate cost estimates and noise contributions were
determined for these vehicles.
Three scenarios were considered for the CBA, described in section 4.4, including a baseline
scenario, a scenario with half of all noisy vehicles quieter due to the improved regulation and a
scenario with all noisy vehicles quieter. These correspond to the potential effectiveness of improved
regulations.
Accumulated additional industry costs for R&D, production and testing amount to 508 million Euro
over the 20-year appraisal period. If better enforcement and losses of retailers of replacement
exhausts are taken into account, the accumulated costs amount to 1,108 million Euro.
For scenario 3b, described above, which assumes the improved regulation will in time result in
100% reduction of excessive noise by 10 dB for motorcycles and 7 dB for mopeds, the average
reductions of equivalent noise levels for all affected roads are estimated at 0.1 dB reduction for
Northern Europe and at 1.1 dB reduction for Southern Europe. This is considered a realistic
outcome.
Excessive noise from single events would potentially be reduced much more, by 10-15 dB,
significantly reducing annoyance and sleep disturbance. For a noise reduction of 10 dB for
motorcycles and 7 dB for mopeds producing excessive noise, for half of the vehicles (scenario 2b
described above), the benefit-to-cost ratio is 10, and for all the vehicles, 20. If the noise reduction
is actually higher, 15 dB for motorcycles and 10 dB for mopeds producing excessive noise (scenario
2a described above), the benefit to cost ratio is higher too, up to 47 in the extreme case.
For all the scenarios other than the baseline, the benefits well outweigh the costs. This is the case
even for scenario 2b, with only half of the L-category vehicles quieter and with a modest noise
reduction. The benefits for amenity are larger than the health benefits, which are nevertheless
substantial. The largest part of the benefits is due to the Mediterranean countries, where L-category
vehicles form a much larger part of the traffic volume. If the level of enforcement remains the same
without additional expense, and sales loss of illegal exhausts are not taken into account, the benefitto-cost ratio is even larger.
This clearly justifies the proposed improvements to the three regulations. These include
amendments to ensure the stringency and quality of test results with respect to type approval,
market surveillance and enforcement of sound emissions, and correspondence with real life driving
conditions by introducing ASEP.
The CBA could be improved on if the following were available:
 Valuation for noise reduction of single events, especially for L-category vehicles noise.
 Better information on occurrence (roads and times) and noise levels for excessive vehicle
noise.
 Better assessment of the specific cause of excessive noise: non-approved exhaust, wrong
exhaust, tampered exhaust or speed limiter, damaged or malfunctioning exhaust, speeding
or excessively noisy driving, removing or switching off the dB killer.
111
The general result of the CBA is nevertheless expected to be similar or even with a higher benefit
to cost ratio, given that most input data estimates are conservative and actual levels of complaints
about L-category vehicles noise are known to be high in some countries. Due to the relatively high
benefit-to-cost ratio, it can also be concluded that any other measures than improved regulation,
such as better enforcement, will also be cost-effective. In this sense, it would be beneficial to
monitor the effectiveness of the improved regulations before entry into force and several years
afterwards.
112
5
Final conclusions, recommendations and
future perspectives
The main objective of the project was to perform due diligence to UN Regulations Nos 9, 63, 92
before considering their accession into the EU regulatory framework. UN Regulation No. 41 has not
been considered, as this has been already introduced in the EU Regulatory framework. Any
amendments proposed to these three UN Regulations had to be drafted in order to:

Ensure that the UN Regulations Nos. 9, 63 and 92 provide at least the same or, favourably,
improved level of stringency with respect to type-approval, market surveillance and
enforcement requirements, concerning sound emissions, as the EU regulations, and
provide the technical background required for the later introduction of Euro 5 sound level
limits.

Make sure that those three UN Regulations contain the necessary references to and
deliver the minimum test results level which should be used for type-approval, market
surveillance, and enforcement purposes in the EU, concerning sound emissions.
In this section, a summary of the main conclusions of the project is provided, together with
recommendations and points for future discussion and consideration.
5.1 The need for enhanced sound control requirements
of L-category vehicles
According to the findings of a stakeholders’ consultation conducted in the current study, there is still
a lot of room for improvement of sound level control of L-category vehicles. Specifically:
 Noise perceived from L-category vehicles is still considered to be a significant problem for
many European municipalities and public authorities. The problem is more intense in urban
and rural areas, compared to motorways where this is considered less of a problem.
 Most of the perceived noise is considered to come from tampered vehicles and especially
motorcycles; however, mopeds and other L-category vehicles are also considered important.
Vehicles with tuned or modified exhaust systems are a particular annoyance, especially at
night.
 The main cause of perceived noise is identified to be the lack of adequate market surveillance
and enforcement, rather than the type-approval procedure and the limits per se, for which
there is still space for improvement.
 The majority (80%) of the participants of the survey would like to see more done towards
better noise control and have made a number of recommendations, including the following:
o
Introduce more anti-tampering measures, perform better market surveillance and
better enforcement of regulations (e.g. by police control, roadside checks, more
effective periodic technical inspection checks).
o
Improve sound emission tests to better reflect real driving road conditions and
better check of sound emission in motion (for both new and in-use vehicles).
o
Prohibit defeat devices and easy tampering by proper design measures.
o
Impede removal/modification of individual parts from an approved silencer.
o
Be aware that more strict limits in general can help towards reducing noise, but
there are some concerns that this measure alone is not sufficient (i.e. if not
combined with better enforcement in practice).
113
 In general, the main obstacles for effective noise suppression are believed to be the following:
o
Periodic technical inspection and in-service conformity testing is not conducted in
all EU Member States.
o
The stationary sound test is not always representative of actual levels from the
vehicle in motion under real driving conditions.
o
There are many possibilities to circumvent testing results, i.e., shutters, parts that
can be ‘loosened’ or removed easily without the TA marking being damaged, etc.;
shadow modifications cannot always be checked (e.g. internal exhaust
modifications).
o
As silencers are easy to replace (original to replacement unit and vice versa), often
an aftermarket silencer is fitted for normal road use which is temporarily replaced
by the original silencer just for the periodic technical inspection. The aftermarket
silencer is not always type approved.
o
Complex sound check tests are not always easy to be performed by police;
moreover, there is often lack of trained staff, budget, resources, and equipment for
effective noise control.
 Specific suggestions regarding replacement silencers, in view of reducing tampering and
making original components easily recognisable by test and enforcement authorities, include:
o
Use of an official label on the vehicle frame/main part or an official electronic
database (e.g. available via Internet), where the legal mounted silencer or the
replacement exhaust silencer system (RESS) is mentioned and all reference and
practical information is included (i.e. vehicle manufacturer, vehicle type, trade
name, engine capacity, engine power, model years applicable, other remarks).
o
A special sticker with a sign indicating that a product is compliant with sound
regulations could be effective in this sense, together with an awareness campaign
for customers on labelling of compliant products (e.g. similar to EU tyre rating).
o
Ensure that the ‘E’ mark remains clearly visible and cannot be easily removed or
‘polished’ out; moreover, ensure that tampering of 'E' marked exhaust systems is
not straightforward.
5.2 Amendments introduced to UN Regulations
In response to the needs expressed by the stakeholders, the recommendations put forward, and
the objectives of the study as such, a number of amendments were introduced to the related UN
Regulations. Further to amendments of mostly editorial nature, a number of substantiated revisions
were done to improve the Regulations, in particular with regard to removing potential loopholes in
the tests and removing ambiguities for special cases. The key technical amendments that were
adopted at the 64th UNECE Working Party on Noise (GRB) meeting in September 2016 can be
summarized to the following:

Amendments in UN Regulation No. 92, in order to better control the quality and
effectiveness of non-original replacement exhaust silencing systems (NORESS), which
were clearly identified as one of the problems related to excessive noise. The most
significant revisions included:
o
Paragraph 6.3, included additional technical requirements in order to hinder
NORESS tampering or other manipulation:
6.3.1
Tampering protection provisions
114
6.3.2 Multi-mode NORESS, where such a system should be compliant with
sound
limits in all its modes
6.3.3
Explicit prohibition of ‘defeat’ devices
6.3.4 Required additional sound emissions provisions (ASEP) for NORESS
intended to be used for L-category vehicles approved in accordance with UN R4104
o
Annex 1: Two communication forms proposed to clearly distinguish NORESS for
vehicles approved in accordance with UN Regulation No. 41-04 from those
approved in accordance with UN Regulations Nos. 9 or 63, in order to differentiate
testing conditions and ASEP and better guide market surveillance authorities.
o
Annex 3: Differentiation of conditioning method for fibrous absorbent materials
used in NORESS in accordance with the UN Regulation under which the vehicle
of NORESS installation is approved, to make testing severity proportional to the
vehicle category the NORESS is going to be used for.
o
Annex 4: Statement of Compliance with ASEP of NORESS installed on vehicles
approved in accordance with UN Regulation No. 41-04, to assist market
surveillance authorities.
 Amendments in UN Regulations Nos. 9 and 63 to clarify testing and vehicle condition at typeapproval and to provide better information for vehicle inspection and maintenance. More
specifically:

o
Inclusion of more detailed data for the engine (incl. electric motor, if applicable) and
transmission as well as reference data for in use compliance testing included in
Annex 1 (Communication) for these vehicles.
o
A number of technical revisions in paragraphs 2 and 3 of annex 3 related to the
type-approval test execution, including improved specifications for the test site, the
weather conditions and the background noise correction, as well as the vehicle
condition during testing. The amendments were intended to remove ambiguity and
to reflect testing conditions that better reflect real-life operation.
o
A new paragraph 4 added in Annex 3 in proportionality to UN Regulation No. 4104 intended to provide all necessary information for in-use compliance tests with
the vehicle in motion, in order to assist in-use compliance checking of the vehicle.
o
Enhanced approval marking requirements of original silencers containing fibrous
absorbing materials added in paragraph 5 of Annex 3, to assist market surveillance
authorities.
o
Finally, a transitional period of 5 years till the full application of the proposed
supplements was introduced to allow the necessary lead time for development and
registration.
A new Annex 4 in UN Regulation No. 9, clarifying the sound limits for the different vehicle
subcategories to remove ambiguity.
5.3 Costs and benefits of the proposed amendments
Based on the amendments introduced, a cost-benefit analysis was then performed to examine
whether the amended UN Regulations Nos. 9, 63 and 92 would lead to an overall benefit (expressed
in monetary terms) compared to the costs entailed for development of the new systems, monitoring,
and enforcement. The benefits included amenity and health benefits, while the costs included those
115
for vehicle manufacturers, replacement exhaust retailers, and enforcement authorities. The analysis
was performed over an appraisal period of 20 years starting in 2016.
Three scenarios were considered for the CBA, corresponding to the potential effectiveness of the
improved Regulations. The first scenario (baseline) assumed no change compared to current
levels. In the two alternative scenarios other than the baseline, two degrees of elimination of
excessive noise were considered as a consequence of the agreed amendments. In one of them,
50% of the excess sound emission of in-use vehicles are considered to be eliminated and, in the
most optimistic scenario, all of the excessive sound emitting vehicles are eliminated.
In both alternative scenarios, benefits in monetary terms were found to exceed costs beyond doubt.
The largest part of the benefits was estimated to arise in the EU Mediterranean countries, where Lcategory vehicles correspond to a much larger part of the total traffic activity than in central and
northern EU countries.
This clearly justifies the proposed improvements to the three Regulations, including amendments
to ensure the stringency and quality of test results with respect to type approval, market surveillance
and enforcement of sound emissions, and correspondence with real life driving conditions by
introducing ASEP where appropriate in UN Regulation No. 92.
Moreover, as in our CBA we adopted a rather conservative approach and we came up with a
relatively high benefits-to-cost ratio, it can also be concluded that additional measures to the
proposed amendments, such as better enforcement and more frequent on-road checks, would
possibly turn to be cost-effective.
5.4 Directions for follow-up work
Based on the results of this study and the suggestion from the cost-benefit analysis that additional
measures can have a positive benefits-to-cost balance, a number of directions can be proposed for
follow-up work. Key areas where further improvements can be expected are summarised to the
following:

Stationary roadside tests may only be partially effective, because silencers can be tuned to
perform well at stationary conditions but permit high sound levels when used in acceleration
mode. Although specifying a roadside or inspection and maintenance test including vehicle
acceleration is technically demanding, this is an area that could potentially lead to large
improvements.

Optimizing vehicle allocation to the UN Regulations may still be relevant. For example, L2e
vehicles are technically far more similar to L1e ones, in terms of powertrain and sound
control systems, hence their coverage by UN Regulation No. 63 instead than UN
Regulation No. 9 would be advisable. Similarly, moving L4e vehicles under the coverage
of UN Regulation No. 41 makes sense, given the almost identical specifications of L3e and
L4e (this being an L3e vehicle with sidecar).

ASEP proposals for high powered L5e (not intended for the carriage of goods) and L6e or
special L7e vehicles were submitted to GRB, but will require further study, given that today
these can only be based on UN Regulation No. 41 ASEP. In general, for the L5e vehicles
designed for the carriage of passengers, the same measurement method as for L3e
vehicles should be applied, but there may be differences (in terms of measurement
procedures) between L3e and L5e vehicles designed for the carriage of goods (L5e-B) that
need to be addressed.

The regulations may still be further improved to close remaining loopholes for a ‘defeat
device’ approach. For example, the strict control of entry speed for the pass-by test may
give ground for sound optimisation at acceleration at this speed only.
116

Reference to ISO standards has the drawback that these standards are not publicly
available free of charge. Hence, it would be extremely helpful to the progress of future
improvements in the UN Regulations if the UNECE could ensure that these standards will
be made available to GRB, when references to these standards are made in UNECE
Regulations. An example is the inclusion of requirements for hybrid electric vehicles in UN
Regulations Nos. 9 and 41, based on power-to-mass ratio, after the ISO work on system
power specifications is accomplished.
117
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CALM Workshop, Brussels, Belgium.
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Steven, H., 2004. Noise Emission of Road Transport. Presentation CALM Workshop, Brussels,
Belgium.
Van Zyl, S. et.al., 2012. Potential Benefits of Triple-A Tyres in the Netherlands. TNO report TNO
2014 R10735, Delft, The Netherlands.
Vos, J., 2006. Noise annoyance caused by mopeds and other traffic sources. Proceedings
Internoise 2006, Honolulu.
Vougias, S, Natsinas, Th., 1986. Correlation of vehicular noise to various traffic and geometrical
characteristics in Thessaloniki, Greece, Applied Acoustics, 19, 421-432.
Waterman, E., 2014. Geluid motoren op Lekdijk nader geanalyseerd (Further analysis of
motorcycle noise on the Lek Dike). http://www.geluidnieuws.nl/2014/nov2014/motor3.html.
119
Annex I: Questionnaire that has been used
Questionnaire version A
Questionnaireon
EnhancedsoundrequirementsforL‐categoryvehicles,
i.e.mopeds,quadsandtheirreplacementsilencers
Some Background The European Commission (DG GROW)4 has assigned TNO5 (NL), LAT/AUTH6 (GR), TÜV NORD7 (DE), and HSDAC8 (DE) with the task to perform due diligence on noise control regulations for L‐cat vehicles proposed at UN level (Regs. Nos 9, 63 and 92) before considering their accession into the EU type approval system. The study aims at identifying whether the UN Regulations appropriately fit into the EU context and should propose improvements, if so required. Particular emphasis is given on consideration of tools enabling market surveillance and enforcement of the relevant legislation. The outcome of this work is expected to ensure regulatory enforcement and international harmonization of technical sound provisions through a rationalized and flexible regulatory framework, as well as to protect the environment and human health. To guide this procedure, this questionnaire aims at collecting your input with regard to the following dimensions of noise control from L‐category vehicles: - Impacts: e.g. effects of noise of such vehicles and impacts on citizens’ well‐being. - Type‐approval: procedure followed, effectiveness, and suggested improvements. - Market surveillance and enforcement: effectiveness of current procedures, in particular for replacement parts. What we need from you  Please feel free to answer only the questions you are familiar with! We understand there is a diverse set of questions and some of them are highly technical, so it is ok if you do not address them.  You can substantiate your input (if possible) by documents, references to literature and practical examples, own measurements, or any other suitable information that can help improve the legislation. 4
European Commission, Directorate‐General for Internal Market, Industry, Entrepreneurship and SMEs, Brussels, Belgium. Contact persons: Mr Andreas Vosinis ([email protected]) and Mr Guido Gielen ([email protected]). 5
https://www.tno.nl/en/ 6
http://lat.eng.auth.gr/ 7
https://www.tuv‐nord.com/en/index.htm 8
Heinz.Steven@t‐online.de 120
 If you think it takes too much time to fill in the questionnaire or that it does not provide the framework of what you would like to respond to, please arrange a phone call with Dr. Leonidas Ntziachristos ([email protected], +30 2310 996003).  Feel free to forward the questionnaire to other relevant experts in your company/institution.  We would appreciate receiving your feedback until 10 November 2015. 121
Questions Section 1: Environmental and social aspects of noise pollution from L‐category vehicles9 Q1. Do you consider noise from L‐category vehicles to still be a significant problem? □ Yes □ No □ Partially Q2. Which areas do you consider that are mostly affected? □ Urban □ Rural □ Motorways □ All □ None Q3. During which period of year do you consider that the problem is more intense? □ Work days □ Weekends □ Holiday periods □ All □ None Q4. In a typical urban neighbourhood, noisy L‐cat vehicles are: □ Disturbing □ Rather disturbing □ I like this sound! □ Not a problem Q5. As a pedestrian or cyclist, I am threatened by L‐cat vehicles because their noise distracts my attention. □ Yes □ No □ Not a problem Q6. If you believe that noise from L‐cat vehicles is a problem, can you rate from 1 (main responsible) to 4 (less responsible) who is responsible for this?  The non effective regulations  The weak enforcement of regulations  The industry  The drivers that illegally tune their vehicles Please justify your answer: Q7. Most of the noise comes from □ Motorcycles □ Mopeds □ Other L‐cat vehicles □ Tampered vehicles □ All of the above □ I cannot distinguish Q8. If you are a rider/driver of an L‐cat vehicle, how would you rate the noise of your vehicle? □ Satisfactory □ I want this to be louder □ Needs to be more silent □ Other (please specify) Q9. If you have been a motorcycle10 owner, have you ever replaced your vehicle’s silencer? □ Yes □ No 9
Please consider all L‐cat vehicles (mopeds, motorcycles, quads, tricycles, etc.). Unless otherwise specified, the term ‘motorcycle’ in the questionnaire usually means all L‐cat vehicles. 10
122
Q10. If you answered “Yes” in Q9, what was the prime reason for replacing your silencer? □ Better looks □ Improved noise □ More power □ All of these □ Other (please specify) Q11. Would you like to see more strict regulation in controlling noise from L‐cat vehicles? □ Yes □ No □ I am not interested Q12. For a motorcycle costing 5,000 Euros, would you spend 100 Euros more when purchasing it for better control of its noise? □ Yes, provided this would not lead to loss of power □No, this is too much □ Yes, and even more if so needed □ No, I like the noise exhaust Section 2: Technical issues related to noise control regulations Q13. Are you familiar with the type approval (TA) procedure for noise control of L‐cat vehicles? □ Yes □ No □ Partially □ Other (please specify) Q14. Are there any elements of the regulation that you believe are ineffective? □ Yes □ No □ I don’t know Please justify your answer: Q15. Would you like to make specific suggestions for improvement of the TA procedure? Please specify: Section 3: Market surveillance and enforcement Q16. Are you familiar with the procedure followed by market surveillance and enforcement authorities for noise control of L‐cat vehicles? □ Yes □ No □ Partially □ Other (please specify) Q17. Do you consider the information currently provided to these authorities enough to enable the effective noise control of L‐cat vehicles? □ Yes □ No □ Partially Please justify your answer: Q18. Which do you consider are the main obstacles for effective noise control? Please specify: 123
Q19. Would you like to make specific suggestions for improvement of the market surveillance, monitoring and enforcement procedure? Please specify: References and other points Q20. Please provide any other comments or remarks not addressed above. Q21. Please provide references for further details to the extent possible (documents, literature, practical examples, own measurements, etc.). Personal and institutional information Q22.Please state your name, company/institution and responsibility, e‐mail, telephone number, etc. Name: Affiliation11: Responsibility: E‐mail: Tel. number: Web site: 11
Name of your company or institution, organization, association, authority, etc. If you are representing e.g. an association, please provide some details, e.g. the number of members of your association, scope, etc. 124
Questionnaire version B
Questionnaireon
EnhancedsoundrequirementsforL‐categoryvehicles,
i.e.mopeds,quadsandtheirreplacementsilencers
Some Background The European Commission (DG GROW)12 has assigned TNO13 (NL), LAT/AUTH14 (GR), TÜV NORD15 (DE), and HSDAC16 (DE) with the task to perform due diligence on noise control regulations for L‐cat vehicles proposed at UN level (Regs. Nos 9, 63 and 92) before considering their accession into the EU type approval system. The study aims at identifying whether the UN Regulations appropriately fit into the EU context and should propose improvements, if so required. Particular emphasis is given on consideration of tools enabling market surveillance and enforcement of the relevant legislation. The outcome of this work is expected to ensure regulatory enforcement and international harmonization of technical sound provisions through a rationalized and flexible regulatory framework, as well as to protect the environment and human health. To guide this procedure, this questionnaire aims at collecting your input with regard to the following dimensions of noise control from L‐category vehicles: - Type‐approval: procedure followed, effectiveness, and suggested improvements. - Market surveillance and enforcement: effectiveness of current procedures, in particular for replacement parts. - Impacts: e.g. effects of noise of such vehicles and impacts on citizens’ well‐being. What we need from you  Please feel free to answer only the questions you are familiar with! We understand there is a diverse set of questions, so it is ok if you do not address all of them.  You can substantiate your input (if possible) by documents, references to literature and practical examples, own measurements, or any other suitable information that can help improve the legislation.  If you think it takes too much time to fill in the questionnaire or that it does not provide the framework of what you would like to respond to, please arrange a phone call with Dr. Leonidas Ntziachristos ([email protected], +30 2310 996003).  Feel free to forward the questionnaire to other relevant experts in your company/institution.  We would appreciate receiving your feedback until 10 November 2015. 12
European Commission, Directorate‐General for Internal Market, Industry, Entrepreneurship and SMEs, Brussels, Belgium. Contact persons: Mr Andreas Vosinis ([email protected]) and Mr Guido Gielen ([email protected]). 13
https://www.tno.nl/en/ 14
http://lat.eng.auth.gr/ 15
https://www.tuv‐nord.com/en/index.htm 16
Heinz.Steven@t‐online.de 125
Questions Section 1: Technical issues related to noise control regulations Q1. How would you rate the overall TA procedure for noise control of L‐cat vehicles? □ Easy to follow □ Complicated □ Needs improvement □Other (please specify) Please justify your answer: Q2. Do you encounter specific technical complications during the TA procedure for any of the L‐cat vehicle types? □ Yes □ No □ Partially Please justify your answer: Q3. Are there any elements of the regulation that you believe are ineffective? □ Yes □ No □ I don’t know Please justify your answer: Q4. Would you like to make specific suggestions for improvement of the TA procedure? Please specify: Q5. How would you rate the incurred cost of the TA procedure for noise control? □ High □ Acceptable □ Low Please justify your answer: Q6. Would you like to make specific suggestions for improving the cost in Q5? Please specify: Section 2: Market surveillance and enforcement Q7. Do you consider the information currently provided to market surveillance and enforcement authorities enough to enable the effective noise control of L‐cat vehicles? □ Yes □ No □ Partially □ Other (please specify) Q8. Which do you consider are the main obstacles for effective noise control? Please specify: Q9. Do you receive complaints about the noise from L‐cat vehicles? □ Yes, almost every day □ Yes, sometimes □ Very scarcely □ No, not at all Q10. What is the pattern of check and the approach that you use for noise control of L‐cat vehicles? 126
Please specify: Q11. How do you ensure that replacement silencers comply with legislation? Please specify: Q12. Would you like to make specific suggestions on how to improve compliance information of replacement silencers? Please specify: Q13. Would you like to make specific suggestions for improvement of the market surveillance, monitoring and enforcement procedure? Please specify: Section 3: Environmental and social aspects of noise pollution from L‐category vehicles17 Q14. If you believe that noise from L‐cat vehicles is a problem, can you rate from 1 (main responsible) to 4 (less responsible) who is responsible for this?  The non effective regulations  The weak enforcement of regulations  The industry  The drivers that illegally tune their vehicles Please justify your answer: Q15. Most of the noise comes from □ Motorcycles □ Mopeds □ Other L‐cat vehicles □ Tampered vehicles □ All of the above □ I cannot distinguish Q16. According to your experience, what is the percentage of motorcycle18 owners that replace their vehicle silencer? □ <10% □ 10‐30% □ 30‐50% □ >50%
Q17. What do you think is the prime reason for a motorcycle owner to replace his/her vehicle silencer? □ Better looks □ Improved noise □ More power □ All of these □ Other (please specify) Q18. Would you like to see more strict regulation in controlling noise from L‐cat vehicles? □ Yes □ No □ I am not interested If “Yes”, can you please specify on which field (e.g. sound limits, anti‐tampering, etc.): 17
18
Please consider all L‐cat vehicles (mopeds, motorcycles, quads, tricycles, etc.). Unless otherwise specified, the term ‘motorcycle’ in the questionnaire usually means all L‐cat vehicles. 127
Q19. According to your experience, do you believe that the candidate buyer of a motorcycle costing 5,000 Euros, would spend 100 Euros more when purchasing it for better control of its noise? □ Yes, provided this would not lead to loss of power □No, this is too much □ Yes, and even more if so needed □ No, he/she likes the noise exhaust References and other points Q20. Please provide any other comments or remarks not addressed above. Q21. Please provide references for further details to the extent possible (documents, literature, practical examples, own measurements, etc.). Personal and institutional information Q22.Please state your name, company/institution and responsibility, e‐mail, telephone number, etc. Name: Affiliation19: Responsibility: E‐mail: Tel. number: Web site: 19
Name of your company or institution, organization, association, authority, etc. If you are representing e.g. an association, please provide some details, e.g. the number of members of your association, scope, etc. 128
Annex II: Filled in questionnaires received
[Separate file:]
“Annex II - Answers.zip”
129
Annex III: Collection and processing of
responses
[Separate file:]
“Annex III - L-Vehs Noise Questionnaire.xlsx”
130
Annex IV: Amended UN Regulations
[Separate files:]
“Annex IVa - R9 - ECE-TRANS-WP.29-GRB-2016-06e.docx”
“Annex IVa - R63 - ECE-TRANS-WP.29-GRB-2016-07e.docx”
“Annex IVa - R92 - ECE-TRANS-WP.29-GRB-2016-05e.docx”
131
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ET-01-15-768-EN-N
doi: 10.2873/054474