1. SIAM – 2 Wheeler Group Meeting 11th October 2012
Mahindra 2 Wheelers views on TVS Motor comments on “Optional Side Lighting For 2Ws”
SIAM – 2 Wheeler Group Meeting
11th October 2012

2. Background
When there is no sufficient light on road, while dismounting from 2W, the rider and in particular lady pillion can not see the surface condition of ground and immediate surroundings.
This is particularly seen in rural areas.
In such a condition, their feet may fall on harmful objects, stones, ditches, uneven surfaces, mud, water etc. and may have to walk on such surfaces.
In such events the persons have to face inconvenience.
Also, in such areas there is no light available for minor repairs e.g. removal of wheel for puncture repairs etc.

3. SITUATION IN 4W
ECE R 48 rev 06 permits an optional additional lamp called as “External Courtesy Lamp” to resolve such difficulties.
WP.29, in its’ 156th session agreed further boundary conditions for such lamps. The session also further permitted “Maneuvering lamp.” Reference documents are: ECE/TRANS/WP.29/2012/10 and 11.

4. External Courtesy Light – 4W
45°

5. External Courtesy Light – 4W=

6. Typical Field of Illumination of Courtesy Lamps – 4W
Illumination area with courtesy lamp in outer mirror
Illumination area with courtesy lamp
In side skirt

7. Proposal
Considering the improvement in road safety and convenience of customers, we propose similar lamp (s) in case of 2W and 3W.
Boundary conditions to suit Indian conditions could be: -
Activated only when Front or rear position light is ON and
Either engine is stopped or when vehicle speed is below say 10 km/h.
Apparent surface of White light should not be directly visible in specified zone.
The light shall have automatic off after a lapse of 60 seconds max after activation and / or off can be rider controlled.
Such conditions are in line with 4W regulations.
One of the examples of such light (s) is mentioned in next slide.

8. Courtesy Light – 2W

9. Points:
TVS Motor comments: TVS is not against the feature in 2W/3W like the pass switch (provided in some of the 2W)
Mahindra 2 Wheelers views: MTWL are thankful to TVS for helping in promoting the Side Lights.
TVS Motor comments: TVS is against incorporating in the current AIS 009 (as an optional) in the name of safety
Mahindra 2 Wheelers views: MTWL had already agreed that more emphasis will be given in our Presentation on convenience in addition to safety. However, we are unable to understand why there is objection in incorporating this optional feature in current AIS 009 particularly when we can give better convenience to the customer.

10. Cont…
TVS Motor comments: There is no ban in CMVR as of now to add this feature or any other lighting other than red light in the front or white light in the rear. The OEMs are free to use additional feature of side lights.
Mahindra 2 Wheelers views: If all Two wheelers manufacturers are of this opinion then we can take-up with Test agencies to allow this feature. However, we hope TVS has considered Clause No of AIS and Clause no 5.17 of AIS with particular reference to feature that the light will be ON, when the vehicle speed drop below 10 km/h. Meanwhile, please note that, in CSR meeting held on 3rd & 4th July 2012 at Hotel Radisson, New Delhi, Mr. Balaraman, panel chairman suggested to prepare amendment to AIS 009.

11. AIS 009 Clauses Clause 4.2.2 of AIS 009-2001
Lamps other than those listed in table 1, permitted for M1 and N1 category as per AIS are also permitted.
AIS 008 – or its’ revision does not permit these since ECE R48 was amended later.
Clause 5.17 of AIS
Fitting of any lighting and light signalling devices other than those listed in 5.14 and 5.15 is prohibited for the purpose of type approval.
We would like to fit only lamps which are type approved as per this requirement.

12. Cont…
TVS Motor comments: Already debate is going on to mandate AHO / DRL to improve the conspicuity / safety of motorcycle. In the event of this requirement getting mandated at a later point of time, the electrical connections requirement will activate side lamps also in day time.
Mahindra 2 Wheelers views: The condition that side light can become ON when there is a feasibility of front position light becoming ON was mentioned to identify that these lights can be ON in the ‘Evening & Night’ conditions only and not during Day running.
In case AHO/DRL becomes mandatory later, system can be developed to identify when side lights can become ON. Also, necessary amendments can be worked out while amendment/ revision for AHO/DRLs are planned for introduction into the standard.

13. Cont…
TVS Motor comments: Further as per the electrical connections requirement, the side lamp will activate only when the front position lamp is on. In some of the 2W, the front position lamp is ON only when the engine in ON. When the engine is off, no lights will be ON including side light.
Mahindra 2 Wheelers views: It is possible to develop a system wherein, even if the engine if ‘OFF’ the side lights can be ‘ON’. Further, since the feature is optional, if manufacturers don’t want to take advantage of the feature, then they can avoid it.
TVS Motor comments: This is not going to help anyway for removing wheel assembly in case of puncture. Hence the justification for providing side light is not appropriate from the point of view of wheel removal.
Mahindra 2 Wheelers views: The possibility of using the system for wheel removal has to be decided by the manufacturers and educate the customers accordingly. However, we can modify the justification to clarify the above point.

14. Cont…
TVS Motor comments: This is not the case with M&N category since all the electrical systems are connected to battery.
Mahindra 2 Wheelers views: Yes
TVS Motor comments: Cannot equate the additional passive safety feature given as optional in M & N category (such as side light /courtesy lamp etc.) to motorcycle which are typically naked in nature.
Mahindra 2 Wheelers views: Considering that the feature is useful for illumination of the road on sides, it can be in both cases whether it is M&N category or L category vehicles. The reasoning that the motorcycles are necked in nature does not come in a way to satisfy the need.

15. Other Comments
HD – Concern on mandating if justification relates to safety. The wattage will not sufficient for illumination for wheel removal.
MTWL VIEW – We are projecting this as optional fitment. We have already agreed to down play safety.
As agreed earlier we can modify the justification based on manufacturers explanation.
Yamaha – Against incorporation in AIS 009.
Explanation is already given above w.r.t. TVS comments.

16. Request
We are of the view that such lamps should not be used unless there is an agreement in totality.
Request SIAM members to discuss the proposal and permit us take up this forward.

17. Thank you

18. Optional Side Lighting For 2Ws
For going to AISC
MTWL
Against going to AISC
TVS
HMSI
India Yamaha
Hero MotoCorp
Bajaj
Royal Enfield
Suzuki
Piaggio HD