Study on the availability of anti-lock braking systems for agriculturalDraft and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

Final Report

Written by: A J Scarlett (Scarlett Research Ltd), I M Knight (Apollo Vehicle Safety Ltd) and P A Morgan (TRL Limited) August – 2017

This document does not represent an official position of the European Commission. The suggestions contained in this document do not prejudge the form and content of any possible position by the European Commission.Draft

Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs

2017

Draft

EUROPEAN COMMISSION Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs Directorate C — Industrial Transformation and Advanced Value Chains Unit C.4 — Automotive and Mobility Industries

Contact: Andreas Vosinis

E-mail: [email protected]

European Commission B-1049 Brussels

August 2017

EUROPEAN COMMISSION

Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40Draft km/h and 60 km/h

Final Report

Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs

2017

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ISBN 978-92-79-70240-2 doi:10.2873/580390

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

Table of contents Table of contents ...... 1 Executive summary ...... 3 Glossary of symbols, abbreviations and industry body acronyms ...... 5 1 Introduction ...... 7 1.1 Background to the investigation ...... 7 1.2 Information gathering methodology ...... 8 1.3 Structure of the report ...... 9 2 Classification and selection of agricultural vehicles, trailers and interchangeable towed equipment ...... 11 2.1 Agricultural vehicle, trailer and interchangeable towed equipment categories...... 11 2.2 Vehicle categories excluded from the investigation scope ...... 12 2.3 Vehicle categories included in the investigation scope ...... 17 2.4 Summary of vehicle categories ...... 28 3 Current andDraft future usage of agricultural vehicles in the EU...... 29 3.1 Changes in the nature of agricultural operations and farming ...... 29 3.2 The rationale for increased speed ...... 32 3.3 The EU agricultural vehicle fleet ...... 35 3.4 Existing legislation and policy regarding on-road use of agricultural vehicles ...... 47 4 Accidents related to agricultural vehicles...... 51 4.1 Influence of speed on injury risk ...... 51 4.2 Effect of Mass on Injury Severity ...... 55 4.3 Review of accident data for all agricultural vehicles ...... 56 4.4 Accidents involving SbS and ATVs ...... 74 5 Overview of anti-lock braking systems (ABS) ...... 77 5.1 Current use of ABS on agricultural vehicles ...... 77 5.2 The effectiveness of ABS ...... 85 5.3 Perception of benefits and impacts of implementing ABS on agricultural vehicles ...... 100 6 Issues affecting the wider implementation of ABS systems on agricultural vehicles ...... 107 6.1 Technical availability ...... 107 6.2 Practical issues associated with ABS installation / implementation ...... 110 6.3 Potential benefits of ABS installation / implementation on agricultural vehicles ...... 116 6.4 Practical availability and economic availability ...... 119 6.5 Summary ...... 121 7 Possible alternative criteria for ABS implementation ...... 123

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

8 Cost benefit analysis ...... 129 8.1 Overview of CBA methodology ...... 129 8.2 Development of CBA scenarios ...... 129 8.3 Costs of ABS when fitted to a new vehicle ...... 131 8.4 The benefits of ABS ...... 132 8.5 Forecasting the distribution of sales by vehicle type and how the fleet changes as a consequence ...... 134 8.6 Developing the business as usual baseline (option 1- remove requirement for ABS) ...... 137 8.7 Estimating and valuing casualty reductions ...... 139 8.8 Results of the CBA ...... 140 9 Analysis and discussion ...... 147 10 Conclusions ...... 151 11 Possible options for amendment of Regulation (EU) 2015/68 ...... 155 11.1 Agricultural Tractors (Category Tb) ...... 155 11.2 Agricultural trailers and interchangeable towed equipment (Categories R3, R4 & S2)...... 156 AcknowledgementsDraft ...... 157 References ...... 157 Annex 1 Review of alternative measures ...... 161 Annex 1.1 Braking measures already in the RVBR ...... 162 Annex 1.2 Control of trailer braking system via drive stick input (CVT Transmission/vehicle travel speed control ...... 162 Annex 1.3 Seat belts ...... 163 Annex 1.4 Roll-Over Protective Structures (ROPS) ...... 163 Annex 1.5 Electronically controlled braking systems (EBS) for trailers ...... 164 Annex 1.6 Vehicle to Vehicle (V2V) Communication ...... 164 Annex 1.7 Electronic Stability Control (ESC) for towing vehicles ...... 166 Annex 1.8 Improved Lighting/Signalling ...... 166 Annex 1.9 Improved conspicuity (by means other than lighting) ...... 167 Annex 1.10 Improved field of vision for tractor driver (e.g. mirrors, close proximity or junction cameras, blind spot proximity alarms) ...... 167 Annex 1.11 Driver assist systems – collision warnings or avoidance systems 168 Annex 1.12 Improved maintenance & roadworthiness checks ...... 168 Annex 1.13 Driver training/education (for drivers of both agricultural vehicles and other vehicles) ...... 169

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

Executive summary Regulation (EU) No 167/2013 sets out in Article 17, together with its delegated act Regulation (EU) 2015/68, the braking safety requirements necessary for EU type- approval of all categories of agricultural and forestry vehicle (AFV). This includes provisions for the use of ABS on such vehicles, set out in Delegated Regulation (EU) 2015/68. TRL was commissioned by the European Commission to undertake an assessment addressing Recital (6) of Regulation (EU) 2015/68 to provide the Commission with the information necessary to amend, as appropriate, the Delegated Regulation for AFVs with a maximum design speed of 40 < Vmax ≤ 60 km/h. It was agreed with the Commission that there was the opportunity to refine the focus of the investigation by excluding those vehicles where ABS is deemed either not to be applicable or is unlikely to be technically supported. This excluded consideration of dedicated forestry vehicles and included agricultural tractors under Category T1, T2 and T4.3, Side-by-Side vehicles or All-Terrain Vehicles when type-approved as agricultural tractors, Category R3 and R4 trailers and Category S2 interchangeable towed equipment. Data to inform the investigation was collated using a multi-faceted approach, comprising stakeholder surveys, face-to-face discussions with stakeholders, and reviews of technical and manufacturer literature, vehicle fleet data, legislation and policy regarding on-road usage of agricultural vehicles, cost data related to ABS development / installation / implementationDraft for agricultural vehicles, and data related to accidents involving agricultural vehicles. However, in some cases the information available was very limited, identifying vehicles by speed capability in fleet and accident data was problematic and cost information relied on responses from a relatively small set of stakeholders. The investigation identified the following  Technical availability: ABS is technically feasible and available for nearly all relevant agricultural vehicle types (Categories Tb, R3b, R4b and S2b). However, the ease and economic feasibility of their installation is currently dependent upon the brake application method / medium used on the vehicle and the physical space available to accommodate system components. Mature pneumatically-based ABS technology is readily-available for use on agricultural tractors (T1b) and also on agricultural trailers/towed equipment (R3b, R4b and S2b). Such ABS systems are already in commercial use on a limited number of T1 tractor models, whilst hydraulic (mineral oil) ABS systems are at advanced stages of product development. Commercially-available hydraulic (brake fluid)-based light / medium truck systems are, based on discussions with industry, understood to be suitable for installation on Category T4.3b vehicles. ABS for other (tractor) categories are either at a proof-of-concept stage or in development (e.g. a commercial hydraulic system for ATVs is expected to be marketed in the very near future). Whilst ABS is readily-available for trailers / towed equipment fitted with pneumatic braking systems, it is not currently available for such vehicles which employ hydraulically-actuated braking systems and may not be brought to the market in the foreseeable future. Such (typically lower-mass, less expensive) trailers / towed equipment would therefore require conversion to pneumatic braking systems to permit ABS installation. However, most trailers / towed equipment intended for V > 40 km/h use tends to feature pneumatic braking systems.  Practical availability and applicability: Vehicle braking system actuation method and/or medium is significant in determining the complexity and associated cost of ABS system installation on agricultural vehicles, particularly as the majority of tractors employ hydraulic (mineral oil) brake actuation systems. The diverse nature of tractor design may well require ABS installation to be approached on a model-range by model-range basis. The space available for

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

installation of some current ABS system components may also present a challenge. ABS implementation also requires installation of wheel speed sensors, but this appears to be a surmountable engineering challenge. For larger (pneumatically-braked) agricultural trailers and interchangeable towed equipment, ABS systems may be installed without difficulty. Smaller vehicle applications are likely to be more costly. ABS systems are not currently available for hydraulically- braked trailers. Valid concerns regarding ABS behaviour during off-road braking have been addressed by the provision of manual or automatic system disablement functionality and/or alternative (slower speed) operating characteristics.  Economic availability: The likely system diversity for ABS implementation on agricultural tractors will potentially increase system installation and development costs, thereby increasing cost to the vehicle user. For reasons of commercial confidentiality it has only been possible for this investigation to estimate potential overall system costs. ABS suppliers have commented that, depending upon production volumes, tractor system costs to Original Equipment (vehicle) Manufacturers (OEMs) may be in the region ~€1000 – €1300, to which installation and vehicle-based development costs must be added. Where offered as optional equipment, tractor manufacturers currently retail ABS at ~€4000–€5000. For agricultural trailers and interchangeable towed equipment, mature pneumatic ABS systems are readily available at an OEM cost of ~€500.  Cost benefit analysis: Based on the net (benefits minus costs) present value

figures, removing the requirement to fit ABS to agricultural vehicles (40 < Vmax ≤ 60 km/h) would result in the best monetary gain (from between €1.3 billion - 3.0 billion).Draft Within this net gain, the ‘cost’ is an increase in the number of fatalities from collisions involving agricultural vehicles. There is substantial uncertainty in the analysis which results in a wide range of estimated effects. However, it can be seen that even at the extremes of the possible ranges, the overall effect of this option is always beneficial with respect to the benefit to cost ratios (BCRs), which are always substantially in excess of 1. This option introduces some non- monetised risks around future investment in agricultural vehicle safety technology. The best BCR is achieved by mandating the fitment of ABS on either all R3b and

R4b trailers or just those of MPMaxles > 12 tonnes, in combination with amending the mandatory requirement for T1b tractors to include only those of Vmax > 50 km/h capability. Such options would however lessen the overall net gain to between €1.0 billion - 2.1 billion. However, the improved BCR comes from the fact that the associated increase in casualties is lessened by proportionally more than the cost of fitting the systems is increased. The non-monetised risks would be lessened in this option. The only new policy options that achieve a BCR of less than one are to fit ABS on all 40 < Vmax ≤ 60 km/h Category T1b, R3b and R4b vehicles or to fit ABS on Category T1b and Categories R3b and R4b vehicles of MPMaxles > 12tonnes. Considering how to balance the overall monetary value, benefit to cost ratio, and non-monetised risks to conclude which option is best overall is a matter for the Commission. The investigation concluded the following:  Technical Availability of ABS: In the majority of instances, systems are readily available for relevant agricultural vehicles.  Applicability of ABS: Systems are applicable for use on relevant agricultural vehicles deemed likely to undertake agricultural transport operations on-road.  Cost Benefit Analysis: The likely costs of ABS implementation on relevant agricultural vehicles of 40 < Vmax ≤ 60 km/h capability are high and are unlikely to be outweighed by monetised savings resulting from reduction in casualty numbers during the 15-year evaluation period.

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

Glossary of symbols, abbreviations and industry body acronyms ABS Anti-Lock Braking System (singular) ADAS Advanced Driver-Assistance System AFV Agricultural or Forestry Vehicle AoH Air-over-Hydraulic ATV All-Terrain Vehicle ATVEA All-Terrain Vehicle Industry European Association AWU Agricultural Work Unit BCR Benefit to Cost Ratio CAP Common Agricultural Policy CBA Cost Benefit Analysis cc Cubic Capacity CEMA European Agricultural Machinery Manufacturers Association CLEPA European Association of Automotive Suppliers CoG Centre-of-Gravity CVT Draft Continuously-Variable Transmission delta_V Change in velocity EBS Electronically-controlled Braking System ESC Electronic Stability Control EU European Union GB Great Britain (i.e. England, Scotland and Wales) GVW Gross Vehicle Weight HGV Heavy Goods Vehicle hp Horse power IIHS Insurance Institute for Highway Safety KE Kinetic Energy KSI Killed and Seriously Injured MPM (Vehicle) Maximum Permissible Mass

MPMaxles Sum of Technically Permissible Masses per axle NAAC National Association of Agricultural Contractors (UK) NTT Narrow-Track Tractors OEM Original Equipment Manufacturer PTW Powered Two Wheeler RAV Relevant Agricultural Vehicle ROPS Roll-Over Protective Structure RVBR Regulation with regards to Vehicle Braking Requirements ((EU) 2015/68) SbS Side-by-Side vehicle TRS Technology Readiness Stage

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

UK United Kingdom (i.e. England, Scotland, Wales and Northern Ireland) ULM (Vehicle) Unladen mass V2V Vehicle 2 Vehicle

Vmax (Vehicle) Maximum design speed

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

1 Introduction

1.1 Background to the investigation Transport, both in terms of commodity haulage and travel to/from fields, has long been recognised as an important activity for vehicles such as agricultural tractors. However, in recent decades, rationalisation has led to the creation of larger farm units, each with a greater geographic spread of land. This trend, together with sales of fewer but larger tractors, has resulted in a reduced labour force being required to travel further from/to the base farmstead to perform operations. Additionally, the scope of application for vehicles such as agricultural tractors has also changed, transportation of goods to/from renewable energy generation plants being an increasingly common operation. As a result of these factors, the prevalence of such vehicles on the highway network has increased significantly. In turn, this has led to the introduction of faster tractors, capable of greater productivity during transport operations. As such, the risks posed to other road users by such vehicles have potentially risen. Low speeds relative to other road traffic, poor maintenance and a lack of visibility are all common factors. The parties most commonly killed or injured are those outside of the agricultural or forestry vehicle (AFV) rather than its occupants. Braking performance is fundamental in ensuring the drivability and functional safety of AFVs during both on-road and off-road operations. One means of potentially improving the braking performance of AFVs is through the use of anti-lock braking systems (ABS), as already demonstratedDraft through their implementation on heavy goods vehicles, where this is now a mature technology. Whilst the speed and mass of these agricultural vehicles has increased over the last decade, improvements in safety systems have not necessarily kept pace with these changes and the use of ABS technology is still not widespread, despite certain similarities with commercial vehicles in terms of, for example, large laden / unladen ratio, varying wheel load distribution, and vehicle combinations with up to two trailers and many degrees of freedom. Regulation (EU) No 167/2013 (European Union, 2013) sets out in Article 17, together with its delegated act Regulation (EU) 2015/68 (European Union, 2015), the braking safety requirements necessary for EU type-approval of all categories of AFV (as defined in Article 4 of Regulation (EU) No 167/2013). These categories are:  Category T: Wheeled tractors.  Category C: Track-laying tractors propelled by endless tracks or a combination of wheels and endless tracks.  Category R: Agricultural trailers.  Category S: Interchangeable towed equipment. This includes provisions for the use of ABS on AFVs, set out in Delegated Regulation (EU) 2015/68 as follows:  Clause 2.2.1.21.1 of Annex 1 of Delegated Regulation (EU) 2015/68 states that "tractors of category Tb with a maximum design speed exceeding 60 km/h shall be equipped with anti-lock braking systems of category 1 in accordance with the requirements of Annex XI."  Clause 2.2.2.16 of Annex 1 of the same Delegated Regulation states that "towed vehicles with a maximum design speed exceeding 60 km/h of categories R3b, R4b and S2b shall be equipped with an anti-lock braking system in accordance with Annex XI." However, no mention is made regarding the use of ABS systems on Category C tractors. This is due to there being practically no (if any) 'fast' (Category Cb) tractors of this type currently available in the European Union (see Section 2.2).

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

Delegated Regulation (EU) 2015/68 also states in Annex 1, Clause 2.2.1.21.2 that "tractors of category Tb with a maximum design speed exceeding 40 km/h and not exceeding 60 km/h shall be equipped with anti-lock braking systems of category 1 in accordance with the requirements of Annex X a) for new vehicle types as from 1 January 2020; and b) for new vehicles as from 1 January 2021." Recital (6) of the Delegated Regulation states that "while anti-lock braking systems are wide-spread for vehicles with a maximum design speed of above 60 km/h and could thus be considered as appropriate and made compulsory as of its application by this Regulation, such systems are not yet widely available for vehicles with a design speed between 40 km/h and 60 km/h. For those vehicles, the introduction of anti-lock braking systems should thus be confirmed after a final assessment by the Commission of the availability of such systems… Should this assessment not confirm that such technology is available or applicable, the Commission should amend this Regulation in order to provide that these requirements will not become applicable to vehicles with a design speed between 40 km/h and 60 km/h." TRL was commissioned by the European Commission to undertake an investigation addressing Recital (6) to provide the Commission with the information necessary to amend, as appropriate, Delegated Regulation (EU) 2015/68. This report presents the findings from that investigation. The investigation was to consider three areas, namely:  The availabilityDraft of ABS on AFVs, i.e. the technical availability and/or the readiness of ABS technologies for application on AFVs.  The applicability of ABS on AFVs, i.e. both the practical applicability and economic feasibility of installing ABS technologies and the likely practical advantages (and/or disadvantages).  A cost-benefit assessment to determine whether benefits from vehicle safety improvements using ABS technologies may counterbalance system implementation costs.

1.2 Information gathering methodology The data required to inform the investigation into ABS technology availability and applicability and to provide input to the Cost Benefit Analysis was collated using a multi- faceted approach, since it was considered that the breadth of information required could not be addressed by a single methodology. The different approaches are summarised as follows:  Stakeholder surveys: Three separate questionnaires were developed, each designed for a different target audience and seeking to gather information relevant to that audience. These were disseminated both online and in MS Word format. o National Approval Authorities, Enforcement Authorities and Technical Services): A total of 140 parties from all EU Member States were contacted. At least six parties reviewed the questionnaire but no completed questionnaires were received; it is suspected that this was due in part to a lack of named contacts within these organisations. Subsequently a modified version of the questionnaire was sent by the European Commission directly to named contacts within National Transport Authorities in all 28 EU Member States. Responses were received from five Member States. o Manufacturers of agricultural tractors (or vehicles type-approved as tractors), agricultural trailers and towed equipment, trailer or trailed equipment axles, and vehicle braking equipment systems: A total of 72

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

manufacturers were contacted. Responses were received from 33 manufacturers across all of the product groups. o Industry Bodies and Social Partners: A total of 156 parties were contacted. Only 12 responses were received.  Stakeholder discussions: To supplement the information from the surveys and manufacturers, these discussions were held between members of the project team and both industry bodies and manufacturers as set out below. These discussions were expected to provide the most useful information for the investigation: o Face-to-face meetings were held with CEMA, CLEPA and ATVEA in March 2017. o Face-to-face meetings, detailed conversations and telephone discussions were held with a range of manufacturers of braking systems and agricultural tractors, side-by-side vehicles, all-terrain vehicles, agricultural trailers and interchangeable towed equipment.  Literature review: A review of technical and manufacturer literature on ABS systems in relation to agricultural vehicles.  Data reviews: These data were sourced directly by the project team or provided by stakeholders and included vehicle fleet data, legislation and policy regarding on-road usage of agricultural vehicles, cost data related to ABS development/installation/implementation for agricultural vehicles, and data related to accidents involving on-road use of agricultural vehicles. The scaleDraft and quality of the data available varied. Where this has impacted on the investigation or required assumptions to be made, this is reflected in the text of this report.

1.3 Structure of the report The structure of the report is as follows:  Section 2 presents the agricultural vehicle categories defined by EU legislation, and highlights those which the investigation focusses upon and those which have been excluded.  Section 3 discusses changes in the nature of agricultural operations and farming over the last 20 years, presents the rationale for increased on-road agricultural vehicle speeds, and presents overviews of the EU agricultural vehicle fleet and existing legislation / policy regarding on-road use of agricultural vehicles.  Section 4 discusses accidents related to agricultural vehicles, including the influence of speed and vehicle mass, and a review of accident data related to the on-road use of agricultural vehicles.  Section 5 presents an overview of ABS systems, addressing the current use of ABS on agricultural vehicles, the effectiveness of ABS and the perceived safety benefits and impacts of implementing ABS on agricultural vehicles. It also identifies those alternative measures perceived by stakeholders as potentially offering equivalent or greater safety benefits with regards to accident reduction when compared to ABS.  Section 6 addresses the wider implementation of ABS on agricultural vehicles, taking into account technical availability, practical issues associated with ABS implementation and installation, the potential practical benefits of ABS fitment, and both the practical and economic availability of ABS systems for agricultural vehicles.  Section 7 outlines possible alternative criteria for ABS implementation such as mass and speed thresholds.  Section 8 presents the Cost Benefit Analysis (CBA), addressing the methodology, scenarios used and inputs. It also presents the full results of the CBA.

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

 Section 9 presents analysis and discussion of the findings from Sections 2-8.  Section 10 presents the conclusions of the project, based on the findings presented in Section 9.  Annex 1 discusses the alternative measures to ABS, as identified in Section 5, that are perceived to offer equivalent or greater safety benefits with regard to accident reduction.

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

2 Classification and selection of agricultural vehicles, trailers and interchangeable towed equipment

2.1 Agricultural vehicle, trailer and interchangeable towed equipment categories The vehicle types initially included in the scope of the investigation are defined in Article 3 of Regulation (EU) No 167/2013 (European Union, 2013) as follows:

 Tractor: Any motorised, wheeled or tracked agricultural or forestry vehicle having at least two axles and a maximum design speed of not less than 6 km/h. It is designed to pull, push, carry and actuate certain interchangeable equipment designed to perform agricultural or forestry work, or to tow agricultural or forestry trailers or equipment; it may be adapted to carry a load in the context of agricultural or forestry work.  Trailer: Any agricultural or forestry vehicle intended mainly to be towed by a tractor and intended mainly to carry loads or to process materials and where the ratio of the technically permissible maximum laden mass to the unladen mass of that vehicle is equal to or greater than 3.0.  Interchangeable towed equipment: Any vehicle used in agriculture or forestry which is designed to be towed by a tractor, changes or adds to its functions, permanently incorporates an implement or is designed to process materials, which may includeDraft a load platform designed and constructed to receive any tools and appliances needed for those purposes and to store temporarily any materials produced or needed during work and where the ratio of the technically permissible maximum laden mass to the unladen mass of that vehicle is less than 3.0. The vehicle categories included in the scope of the investigation are defined within Article 4 of Regulation (EU) No 167/2013, noting that each category is supplemented by the index ‘a’ (for vehicles with a maximum design speed (Vmax) below or equal to 40 km/h), or ‘b’ (for vehicles with a maximum design speed above 40 km/h). The categories can be summarised as follows:

 Category T1: Wheeled tractors of > 600 kg unladen mass (ULM), in running order, and a minimum wheel track width of ≥ 1,150 mm.  Category T2: Wheeled tractors of > 600 kg ULM (in running order), but with narrow wheel track widths, i.e. < 1,150 mm.  Category T3: Wheeled tractors of ≤ 600 kg ULM.  Category T4.1: High-clearance wheeled tractors.  Category T4.2: Extra-wide wheeled tractors.  Category T4.3: Low-clearance, low centre-of-gravity tractors, of ≤ 10,000 kg maximum permissible mass.  Category C: Track-laying tractors propelled by endless tracks or by a combination of wheels and endless tracks (Subcategories are analogous to Category T).  Category R1: Trailers with a sum of technically permissible masses per axle (MPMaxles) of  1,500 kg.  Category R2: Trailers with a sum of technically permissible masses per axle > 1,500 kg but  3,500 kg.  Category R3: Trailers with a sum of technically permissible masses per axle > 3,500 kg but  21,000 kg.

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

 Category R4: Trailers with a sum of technically permissible masses per axle > 21,000 kg.  Category S1: Interchangeable towed equipment with a sum of technically permissible masses per axle  3,500 kg.  Category S2: Interchangeable towed equipment with a sum of technically permissible masses per axle > 3,500 kg.

In addition the following vehicle categories are also included within the study:  Side-by-Side Vehicles (SbSs) type-approved either as Category T1 or T3 (depending upon vehicle mass). These are small motorised vehicles, with at least four wheels, with two or more seating positions intended for a variety of uses primarily on unpaved surfaces and equipped with a steering wheel.  All-Terrain Vehicles (ATVs) type-approved as Category T3. These are motorised vehicles designed to travel on four low pressure tyres on unpaved surfaces, having a seat designed to be straddled by the operator and handlebars for steering control.

2.2 Vehicle categories excluded from the investigation scope Whilst the initial scope of the investigation covered all categories of agricultural and forestry vehicles, it was agreed with the Commission at the commencement of the work that there wasDraft the opportunity to narrow the focus of the investigation, by excluding those vehicles where ABS is deemed either not to be applicable or is unlikely to be technically supported. The following exclusions were agreed with the Commission:

 Dedicated forestry vehicles: Whilst agricultural tractors are sometimes used (with appropriate protective guarding) for farm-based forestry activities, modern forestry vehicles are generally considered as off-road / Non-Road Mobile Machines, are therefore not categorised as tractors and are outside of the scope of Regulation (EU) No 167/2013. Dedicated tree harvesters, incorporating timber processing heads (Figure 2.1 (left)), are used to fell, de-limb and cut timber to length, prior to its extraction to the roadside by specialist forwarder vehicles (Figure 2.1 (right)). Onward transportation is then undertaken by road vehicles. As these specialist forestry machines are not tractors and are not used for on-road transportation of forest products, they and related vehicles (i.e. self-propelled, vehicles designed for use solely in forestry) were excluded from the study.

Figure 2.1: Dedicated forestry harvester (left) and forwarder (right) vehicles (Copyright Ponsse)

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

 Category T3 tractors: These vehicles are not of high mass, are generally not used for road transport operations and in most instances are unlikely to incorporate sufficient build-complexity to support the installation of ABS technology. The mass limitation (≤ 600 kg) of the T3 vehicle category primarily restricts it to what are usually known as “Lawn Tractors” (Figure 2.2 (left)), which frequently incorporate mid-mounted grass cutting equipment for use in larger residential ground care applications. Such vehicles do not generally have > 30 km/h max design speed capability. However it should be noted that ATVs type-approved as Category T3b vehicles were included in the study.

Draft Figure 2.2: Category T3 lawn tractor (left) & Category T4.1 high-clearance tractor (right) (Copyright Kubota & Tecnoma)

 Category T4.1 tractors: These specialist vehicles incorporate raised chassis to enable them to straddle and travel along rows of tall growing crops (> 1 m high) such as vines, olives and field-scale soft-fruit (Figure 2.2 (right)). Such tractors are specifically designed for specialist in-field working and are unlikely to be used for road transport operations; additionally they are likely to suffer from poor stability if used at speeds > 40 km/h. It is also worthwhile noting that, as EU type-approval of Category T4.1 vehicles is not mandatory, manufacturers may alternatively choose to comply with the national regulatory requirements of individual Member States; consequently the installation of ABS may not be a requirement.

Figure 2.3: Category T4.2 tractor in-work (left) and travelling on-road (right) (Copyright CNH Industrial)

 Category T4.2 tractors: These ‘extra-wide’ tractors are characterised by their high engine power and large dimensions. They are primarily intended for in-field operations, are unlikely to undertake any significant road transport, except for

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

travel between field sites (Figure 2.3) and are unlikely to have Vmax > 40 km/h capability. Once again it is worthwhile noting that, as EU type-approval of Category T4.2 vehicles is not mandatory, manufacturers may alternatively choose to comply with the national regulatory requirements of individual Member States. Consequently the installation of ABS may not be a requirement.

 Category C tractors: Historically, track-laying (crawler) tractors were slow speed vehicles fitted with steel tracks (Figure 2.4) and were unsuitable for on-highway use due to the damage caused to the road surface. The small numbers of these vehicles sold today tend to be used for specialist applications and/or in hilly areas. They are not used for transport applications and/or at high speeds.

Draft

Figure 2.4: Steel-tracked Category C track-laying tractors (Copyright SDF) The introduction of rubber-tracked crawlers in the late-1980s enhanced the on-road mobility of track-laying vehicles, but generally they are designed as high-power alternatives to Category T4.2 tractors, intended for in-field heavy draught operations (Figure 2.5). On-road use tends to be limited to travel between the farm and fields. Rubber track or half-track conversions have been developed for wheeled tractors (Figure 2.6), but they are primarily intended to enhance in-field tractive performance. Absence of track / axle suspension tends to limit Vmax to ≤ 40 km. In common with vehicle Categories T4.1 and T4.2, the EU type-approval of Category C vehicles is not mandatory under Regulation (EU) No 167/2013: manufacturers may instead elect to comply with the relevant national regulatory requirements of individual Member States for this vehicle type which, in any case, tends only to be sold in relatively small numbers.

Figure 2.5: Rubber-tracked Category C track-laying tractors (Copyright Scarlett Research & AGCO)

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Figure 2.6: Rubber half-track Category C track-laying tractors (Copyright CNH Industrial)

 Category R1 trailers: This vehicle category, of MPMaxles ≤ 1500 kg, primarily includes small single-axle trailers of up to 1500 – 1750 kg carrying capacity. Smaller capacity trailers, intended for use with ATV and SbS vehicles, tend to limit the vertical drawbar loading applied to the towing vehicle, whereas those designed for use with conventional tractors often increase this parameter by locating the trailer axle towards the rear of the chassis (Figure 2.7 (right)). Regulation (EU) 2015/68 (European Union, 2015) stipulates that all Category R1a trailers and R1b vehiclesDraft of MPMaxles ≤ 750 kg are not required to be fitted with a braking system (Table 2.1). R1b vehicles of 750 < MPMaxles ≤ 1500 kg may be fitted with either an inertia or power-operated braking system. ABS technology is not available for such lightweight, inertia-braked vehicles and so Category R1 vehicles were excluded from the investigation.

Figure 2.7: Example Category R1 agricultural trailers (Copyright Logic & Fleming)

Figure 2.8: Example Category R2 agricultural trailers (Copyright Fliegl & Fleming)

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Table 2.1: Trailed vehicle braking systems permitted by Regulation (EU) 2015/68 (RVBR)

Trailed Vehicle Sum of Technically- Max. Design Speed Required Braking Category Permissible Axle Loads (km/h) System (kg)

R1a m ≤ 1500 Vmax ≤ 40

S1a m ≤ 3500 Vmax ≤ 40 NONE

R1b / S1b m ≤ 750 Vmax ≤ 40

R1b 750 < m ≤ 1500 Vmax > 40 Inertia or Power- S1b m ≤ 3500 V > 40 max operated R2 1500 < m ≤ 3500 R3 3500 < m ≤ 21000 ANY Power-operated R4 m > 21000 (continuous or semi- continuous) S2 m > 3500

V ≤ 30 (brakes not on max Inertia-operated R3a 3500 < m ≤ 8000 all wheels) / 40 (brakes (derogation) on all wheels) Draft  Category R2 trailers: Agricultural trailers of 1500 < MPMaxles ≤ 3500 kg which, in single-axle form, typically equates vehicles of 1500 – 1750 kg to 3000 – 4000 kg carrying capacity (Figure 2.8): this being dependent upon axle location on the chassis and the magnitude of mass transfer to the towing vehicle. Category R2 trailers may be fitted with either an inertia or power-operated braking system (Table 2.1). Consequently they were excluded from the investigation for the reasons given above.  Category S1 interchangeable towed equipment: This vehicle category encompasses a wide range of trailed agricultural implements of MPMaxles ≤ 3500 kg. S1a vehicles (Vmax ≤ 40 km/h) are not required to be fitted with a braking system (Table 2.1), whereas S2b vehicles (Vmax > 40 km/h) may be fitted with either an inertia or power-operated braking system. As explained above, ABS technology was not found to be available for inertia-braked vehicles and, in any case, the gross mass and likely on-road usage of Category S1 vehicles is likely to be limited. They were therefore excluded from the investigation.

Figure 2.9: Category S1 interchangeable towed equipment: Round baler (left) and trailed mower-conditioner (right) (Copyright Kverneland / CEMA)

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2.3 Vehicle categories included in the investigation scope Article 17 of Regulation (EU) No 167/2013 refers to ensuring that agricultural and forestry vehicles "with a maximum design speed of more than 40 km/h meet an equivalent level of functional safety with regard to brake performance and, where appropriate, anti-lock braking systems as motor vehicles and their trailers." The above statement focuses on on-road use of vehicles. It was therefore agreed with the Commission that the focus of this investigation should be further-refined to concentrate upon agricultural tractors, trailers and towed equipment used on- road for operations necessary to agricultural purposes, with an emphasis on larger mass vehicle combinations. The vehicle categories included in the investigation scope were therefore as follows:

2.3.1 Category T1 tractors These wheeled vehicles of > 600 kg ULM and ≥ 1150 mm minimum wheel track width represent the vast majority of ‘conventional’ agricultural tractors sold in the EU. However, due to the broad spectrum of demands placed upon them by users, T1 tractors are manufactured in a very wide range of sizes and capabilities, both in terms of physical dimensions, engine sizes and rated power outputs; such variation also extends to maximum design speed (Vmax) capability. It has been foundDraft that current production T1 tractors may be reliably placed in one of a range of generic size categories (Table 2.2, Figure 2.10 & Figure 2.11), these being based primarily upon vehicle rated engine power, but also considering vehicle wheelbase, unladen mass, max permissible mass, payload and 3-point linkage lift capacity. This investigation has found that, currently, 40 < Vmax ≤ 60 km/h capability is widely available as a customer-specified option on tractors in the High-Power 4 cylinder and Lightweight 6 cylinder categories (generally those of > 130 hp / 97 kW rated engine power) and also in all larger vehicle categories (Lower Middleweight 6 cylinder, Upper Middleweight 6 cylinder and Heavyweight 6 cylinder). These basically cover the rated power range of 130 – 500 hp (97 – 375 kW). The market availability of such vehicles in certain Member States may currently be limited by national road usage legislation (see Section 3.4), but these higher-speed tractors have been offered in certain EU markets since 2003 – 2006 (depending upon vehicle size / power). They therefore represent a key area of focus for this investigation.

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Table 2.2: Generic T1 tractor size categories (Source: Scarlett Research Ltd)

Typical Rated Max. Wheelbase Unladen V > 40 km/h Size Category Power Range (hp Permissible max (m) Mass (kg) available? / kW) Mass (kg)

Low-Power 50 – 75 hp 1.9 – 2.15 1600 - 3000 4000 – 5500 No 3 & 4 cylinder (37 – 56 kW)

Med-Power 75 – 100 hp 2.3 ± 0.2 3000 - 4500 5000 – 8500 No 3 & 4 cylinder (56 – 75 kW)

High-Power 100 – 150 hp 2.55 ± Yes 4500 - 7000 8000 – 10000 4 cylinder (75 – 112 kW) 0.15 (≥130 hp / 97 kW)

Lightweight 100 – 150 hp Yes 2.6 ± 0.1 6000 - 7000 8000 – 10000 6 cylinder (75 – 112 kW) (≥130 hp / 97 kW)

Lower 150 – 230 hp Middleweight 2.9 ± 0.1 7300 - 9000 11500 – 13500 Yes 6 cylinder (112 – 172 kW) Upper 230 – 320 hp 9500 - Middleweight 3.0 ± 0.1 14000 - 17000 Yes 11500 6 cylinder (172 – 239 kW)

Heavyweight 320 – 500 hp 11500 - 3.1 ± 0.05 17000 - 22000 Yes 6 cylinder Draft14000 (239 – 375 kW)

Figure 2.10: Initial generic categories of T1 tractors: Low-power 3 & 4 cylinder (top left), Medium power 3 & 4 cylinder (top right), High-power 4 cylinder (bottom left) and Lightweight 6 cylinder (bottom right) (Copyright Deere & Co, Claas & CNH Industrial)

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Figure 2.11: Remaining T1 tractor categories: Lower Middleweight 6 cylinder (top left), Upper Middleweight 6 cylinder (top right) and Heavyweight 6 cylinder (bottom) (Copyright SDF, CNH Industrial & Deere & Co.)

2.3.2 Category T2 tractors Category T2 tractors are characterised by their narrow overall width and narrow wheel track widths (minimum track width ≤ 1150 mm). Within the industry, T2 tractors are usually referred to as Narrow-Track Tractors (NTT) and are primarily intended for use in applications which require a vehicle of limited overall width. These are often areas of semi-permanent cropping where moderately-tall (> 1 m high) plants are grown in a rectilinear arrangement and tractors are required to travel between each crop row on a regular basis, to perform crop treatment and harvesting operations. Typical examples found within the EU and worldwide include vineyards, orchards, field-scale soft fruit (e.g. raspberries, blackcurrants) and hops (Nathanson, Scarlett, & Barlow, 2014).

Figure 2.12: Example T2 tractors performing crop treatment operations in a vineyard (left) and an orchard (right) (Copyright CNH Industrial)

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Figure 2.13: Example articulated-chassis (left) and rigid chassis (right) Category T2 tractors (Copyright Scarlett Research)

Whilst in-field / vineyard / orchard work typically represents a substantial proportion of the activities undertaken by T2 tractors, during the harvest season they would also be expected to transport the crop back to the farm / processing plant. The time spent during the growing season travelling between the farm and field during crop treatment operations (e.g. agrochemical application) also detracts from daily work output. Consequently rapid and comfortable on-road transport capabilities are desirable T2 vehicle features.Draft To this end the majority of current T2 tractors are offered with Vmax = 40 km/h transmissions either as optional or standard equipment but, at present, no Vmax > 40 km/h T2b tractors are marketed. This is possibly due in part to the virtual necessity of a front axle suspension system to maintain both driver comfort levels and vehicle drivability on rural roads at speeds above 40 km/h. Few T2 tractor manufacturers currently offer this feature, but it may become more widespread in the future and Vmax capability may increase, hence the inclusion of T2 vehicles in this investigation.

2.3.3 Category T4.3 tractors Regulation (EU) No 167/2013 defines T4.3 vehicles as “low-clearance four-wheel drive tractors whose interchangeable equipment is intended for agricultural or forestry use and which are characterised by a supporting frame, equipped with one or more power take-offs, having a technically permissible mass of ≤ 10,000 kg, for which the ratio of this mass to the maximum unladen mass in running order is < 2.5 and having the centre of gravity, measured in relation to the ground using the tyres normally fitted, of less than 850 mm.”

These rather specialised transporter-type vehicles are characterised by their low centre of gravity and consequent very favourable stability characteristics. Whilst they are used both in agricultural and municipal applications, the niche area they fill in agriculture primarily involves operations to support livestock-based farming systems on steeply- sloping fields in Alpine regions. The vehicle’s frame-type chassis accepts alternative bodies for fodder collection, manure / slurry distribution and other purposes (Figure 2.14). The capability of the braking systems offered on these machines reflects their frequent operation on steeply-sloping ground. Both T4.3a (Vmax ≤ 40 km/h) and T4.3b (Vmax ≤ 50 km/h) versions are available, but none are currently offered with ABS. Their Vmax > 40 km/h capability and the fact that they are required to be subject to EU type- approval, resulted in their inclusion within the investigation.

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Figure 2.14: Example T4.3 low-clearance, transporter-type tractors (Copyright Aebi-Schmidt)

2.3.4 Side-by-Side (SbS) vehicles ATVEA (the All-Terrain Vehicle Industry European Association) describes SbS vehicles as small motorised vehicles with at least four wheels, equipped with a steering wheel and with two or more seating positions. They are intended for a variety of uses including leisure and utilityDraft / work tasks (e.g. agriculture and forestry applications), primarily on unpaved surfaces. In agricultural and forestry applications, SbS utility vehicles are designed to perform light-duty tasks for which conventional tractors are too heavy, inconvenient or inefficient. Whilst used for similar purposes and utilising some similar components, SbS vehicles (Figure 2.15) differ from All-Terrain Vehicles (ATVs) due to their size, seating position, and the presence of a rear load-carrying platform and a roll-over protective structure (ROPS). Indeed in certain EU markets (e.g. the United Kingdom (UK; i.e. England, Scotland, Wales and Northern Ireland) agricultural market) SbS utility vehicles are displacing ATVs to an extent, partly because of their greater capability (passenger & load carrying), greater operator comfort (partly or totally enclosed cab) and improved stability on sloping ground.

Figure 2.15: Example SbS vehicles (Copyright ATVEA)

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SbS vehicles come in a wide range of sizes, including 4-wheel and larger 6-wheel variants, but their typical masses and payloads may be summarised as follows:

 Unladen Mass: ~450 – 870 kg.  Payload: ~400 – 700 kg (4 wheel) or ~900 kg (6 wheel).  Towing Capacity: ~500 – 900 kg.

Current SbS engine capacities range from ~400 – 1100 cc, but the larger capacity engines (the most popular in agriculture) are diesel rather than petrol-powered. All SbS makes / models encountered by the investigation were fitted with mechanically- controlled, belt-type continuously-variable transmissions (CVTs). Vehicle suspension and braking system designs were found to be similar to those of ATVs, with independent front and rear wheel suspension being most prevalent and external automotive-type, non- servo-assisted ‘dry’ disc and caliper brakes usually being mounted at the wheel ends. Due to their range of unladen masses, when type-approved as agricultural tractors, individual SbS vehicles may be classified either as Category T3 (ULM ≤ 600 kg) or Category T1 (ULM > 600 kg); in practice the majority fall into the T1 category. Interestingly their (unrestricted) max speed capability can be as high as 90 km/h, but when type-approved as tractors their Vmax is limited electronically (via engine & transmission management systems) to 40 or 60 km/h, depending upon the manufacturer and whether type-approved as Ta or Tb. At the time of writing this report, ABS systems are not currently offered on SbS vehicles; however, their potential high-speed capability and inclusion Draftwithin the tractor type-approval system resulted in their consideration by the investigation.

2.3.5 All-Terrain Vehicles (ATVs) ATVEA describes ATVs as motorised vehicles fitted with four low pressure tyres, designed to travel on unpaved surfaces, having a seat designed to be straddled by the operator and handlebars for steering control (Figure 2.16). ATVs are subdivided into two types as designed by the manufacturer:  Type I: Intended for use by a single operator and no passenger.  Type II: Intended for use by an operator and a passenger.

ATVs are rider-active vehicles, meaning operators are required to shift their body weight to enhance the performance capabilities of the vehicle. This requires special skills and training to ensure safe operation, especially when on challenging off-road terrain. ATVs are widely-sold for leisure and sporting purposes. However within agriculture in addition to being utilised as a convenient form of off-road transport around the farm, often to support livestock rearing activities (Figure 2.16 (right)), they are also utilised with a wide range of mounted or trailed implements to perform tasks for which the physical size and/or mass of a conventional tractor may cause it to be less suitable (Figure 2.17). Due to their low unladen mass (typically ~250 – 325 kg), when type-approved as agricultural vehicles ATVs tend to be classified as Category T3 tractors. Petrol engine capacities vary from ~270 – 950 cc, but most vehicles intended for agricultural use tend to fall within the ~550 – 750 cc range. Independent front and rear wheel suspension is now the most common design. Front wheel brakes tend to be automotive-type ‘dry’ disc and caliper units mounted at the wheel ends, whereas rear brakes are of a similar type or oil-immersed ‘wet’ multi-disc-type fitted in the rear axle / transmission. All are actuated by conventional non-servo-assisted automotive-type hydraulic systems employing brake fluid. At the time of writing, ABS systems are not offered, irrespective of the max speed capability of the vehicles. However, the investigation has been advised that an ATV manufacturer intends to market a Vmax > 60 km/h vehicle, type-approved as an agricultural tractor. This will be fitted with an ABS system to comply with the current requirements of Regulation (EU) 2015/68.

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Figure 2.16: Example single-seat ATV and a typical agricultural use (inspecting livestock) (Copyright KYMCO & ATVEA) Draft

Figure 2.17: Example agricultural uses of ATVs: slug pellet application (top left), field spraying (top right), timber extraction (bottom left) and mowing (bottom right) (Copyright Stocks AG & Logic)

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2.3.6 Category R3 trailers This grouping encompasses agricultural trailers and tractor-towed load carrying vehicles of 3500 < MPMaxles ≤ 21,000 kg. In practice this corresponds to a very wide range of vehicle carrying capacity and consequent design complexity. However, it is important to appreciate that whilst trailers are normally marketed in terms of their carrying capacity, the manner in which this relates to the parameter chosen to categorise such vehicles within the EU type-approval process (sum of the technically-permissible masses per axle,

MPMaxles), is very dependent upon vehicle design configuration. Regulation (EU) 2015/68 (European Union, 2015) further sub-divides Category R and S towed vehicles into one of the following designs categories:

 Drawbar Towed Vehicle: A towed vehicle with at least two axles of which at least one is a steered axle, equipped with a towing device which can move vertically in relation to the towed vehicle and which transmits no significant static vertical load to the tractor.  Centre-axle Towed Vehicle: A towed vehicle where one or more axles are positioned close to the centre of gravity of the vehicle so that, when uniformly loaded, only a small vertical static load, not exceeding 10% of the maximum mass of the towed vehicle or a load Draftof 1000 daN, whichever is less, is transmitted to the tractor.  Rigid drawbar Towed Vehicle: A towed vehicle with one axle or group of axles, fitted with a drawbar which transmits significant (vertical) static load to the tractor due to its construction. The coupling used for a vehicle combination shall not consist of a king pin and a fifth wheel. Some slight vertical movement may occur at a rigid drawbar.

These somewhat lengthy definitions are largely derived from on-road truck-trailer terminology and in this instance have been adapted to suit agricultural trailers and towed equipment. Previous terminology referred to ‘Balanced’ trailers / towed equipment which do not impose a vertical load on the towing vehicle and ‘Unbalanced’ trailers / towed equipment which do transfer mass onto the towing vehicle. In practice few, if any examples of agricultural towed vehicles fall within the ‘Centre-Axle’ definition. The reason for highlighting these definitions and vehicle design variations at this point is as follows. The vast majority of larger (Category R3 and R4) trailers used in the EU are of the Rigid Drawbar / Unbalanced type (Figure 2.18 (left)) which, depending upon their specific design may transfer up to 3000 – 4000 kg of vertical loading onto the towing tractor when fully-laden, thereby greatly assisting in-field tractive performance. ‘Drawbar’ or ‘Balanced’ trailers (Figure 2.18 (right)) are still popular in certain EU member states (mainly Germany), primarily for on-road transport but, it will be appreciated that, for a given MPMaxles value, they generally offer lower carrying capacities (Table 2.3). As Rigid Drawbar-type trailers transfer a significant vertical load onto the towing tractor, for a given MPMaxles value, their total (gross) laden mass will be higher than that of a Drawbar-type trailer of an identical MPMaxles level. The mass-transfer nature of their design requires a more robust construction, which is reflected in a higher unladen mass but, overall, the carrying capacity of the Rigid Drawbar-type vehicle is greater (Table 2.3). This is important to appreciate, particularly given the potential influence of trailer- imposed loadings on the tractor during transport operations.

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Figure 2.18: Example Category R3 trailers: rigid drawbar / unbalanced (left) and drawbar / balanced (right) (Copyright Fliegl / CEMA)

Table 2.3: Influence of agricultural trailer design / configuration upon carrying capacity

Total (Gross) Drawbar MPM Unladen Mass Carrying Trailer Type axles Laden Mass Vertical Load (kg) (kg) Capacity (kg) Draft(kg) (kg) R3 Drawbar 18,000 18,000 4200 0 13,800 (Balanced) R3 Rigid Drawbar 18,000 21,000 5800 3000 15,200 (Unbalanced)

As mentioned previously, the Category R3 trailer 3500 < MPMaxles ≤ 21,000 kg range corresponds to a very wide range of vehicle carrying capacity and design complexity, potentially from a relatively simplistic ~4000 kg carrying capacity single-axle trailer (Figure 2.8 (right)) up to a ~18,000 kg capacity tandem-axle trailer of similar design to that depicted in Figure 2.18 (left). It should also be appreciated that the power output and the Vmax capabilities of the tractors likely to be towing these trailers from either end of the Category R3 range are also likely to be significantly different. Category R3 trailers probably represent the largest proportion of the current EU-28 agricultural trailer fleet which is in regular / frontline use, in many cases at speeds above 40 km/h. Their consideration by this investigation was therefore essential.

2.3.7 Category R4 trailers The R4 category encompasses agricultural or forestry trailers and tractor-towed load carrying vehicles of MPMaxles > 21,000 kg. The national legislation of most EU Member States does not permit such loadings to be carried on only two axles, so Category R4 trailers are generally of tri-axle design (Figure 2.19). In order to enable the towing tractor to generate sufficient tractive effort to effectively tow these large trailers in-field, the majority of vehicle designs are of the Rigid Drawbar type. Given that the vertical load which may be imposed on the tractor is usually limited to ~3000 – 4000 kg by the tractor manufacturer and that few Member States permit imposed loadings of greater than 8000 kg per axle for close-spaced tri-axle trailer bogies (MPMaxles ≤ 24,000 kg), the total laden mass of such Category R4 vehicles is generally limited to ~28,000 kg, resulting in a max carrying capacity of ~21,500 kg. The axles and foundation braking equipment used on such vehicles are very similar if not identical to that found on on-road truck trailers. However, given that the ‘flotation’-type

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Figure 2.19: Example Category R4 agricultural trailers (Copyright Fliegl / CEMA & Claas / Joskin)

It should also Draftbe remembered that Regulation (EU) No 167/2013 defines a trailer as “any agricultural or forestry vehicle intended mainly to be towed by a tractor and intended mainly to carry loads or to process materials and where the ratio of the technically permissible maximum laden mass to the unladen mass of that vehicle is equal to or greater than 3.0.”

Consequently the Category R definition includes what may be regarded as trailed agricultural implements, if their primary purpose is either:- (i) to carry loads, or (ii) to process materials and their Laden : Unladen mass ratio is ≥ 3.0.

Therefore trailed equipment such as those vehicles shown in Figure 2.20 are classified as Category R vehicles. It should be noted that this arrangement applies across the entire Category R vehicle mass range and not just within Category R4.

Figure 2.20: Trailed agricultural implements classified as Category R4 trailers: Tri-axle self-loading forage wagon (left) and slurry tanker (right) (Copyright Pöttinger / CEMA & CNH Industrial / Joskin)

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2.3.8 Category S2 interchangeable towed equipment This vehicle category potentially encompasses an extremely wide range of semi-mounted and trailed agricultural implements (Figure 2.21), from ploughs and cultivators, to seeders, agrochemical application equipment (sprayers), and to a wide variety of trailed, crop-specific harvesting machinery such as mowers, tedders & rakes, balers, forage, potato and sugar beet harvesters. Given that in 2016, in a number of EU Member States ≥ 35% of tractors sold were of ≥ 150 hp / 112 kW rated power (see Section 3.3), the corresponding implements required to effectively utilise these power levels will be capable of considerable work output. This requires a robust implement construction and/or a substantial working width: factors which both contribute to an increase in implement mass. Consequently it is not unrealistic to suggest that the majority of trailed or semi-mounted implements used in modern European agriculture will exceed the

MPMaxles > 3500 kg threshold and fall within the S2 vehicle category. However, it should be remembered that the primary purpose of this equipment is in-field or off-road use and that on-road travel should (in all probability) comprise only a limited amount of their daily operation. Draft

Figure 2.21: Examples of Category S2 interchangeable towed equipment: Semi-mounted reversible plough (top left), seeder (top right), crop sprayer (bottom left) and large square baler (bottom right) (Copyright CEMA & Valtra / Amazone)

To aid practical interpretation of which trailed agricultural machinery may be considered as Category R vehicles and which as Category S, CEMA (European Agricultural Machinery Manufacturers Association) have produced a useful guidance document (CEMA, 2016a; CEMA, 2016b) which illustrates a wide range of modern agricultural trailers and trailed implements and provides pertinent vehicle data.

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2.4 Summary of vehicle categories

Table 2.4 summarises which vehicle categories are included and excluded from further consideration within the investigation.

Table 2.4: Vehicle categories included and excluded from the investigation

Included in the investigation Excluded from the investigation Category T1 tractors Dedicated forestry vehicles Category T2 tractors Category T3 tractors (except for those SbSs and ATVs type approved as Category T3b) Category T4.3 tractors Category T4.1 tractors Side-by-side (SbS) vehicles type-approved as Category T3 or T1 tractors Category T4.2 tractors All-terrain vehicles (ATVs) type-approved as Category C tractors Category T3 tractors Category R1 trailers Category R3 trailers Category R2 trailers Category R4 trailers Category S1 interchangeable towed equipment Category S2 interchangeableDraft towed equipment

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3 Current and future usage of agricultural vehicles in the EU

3.1 Changes in the nature of agricultural operations and farming The last 20 years has witnessed significant changes to European agriculture. Whilst EU Common Agricultural Policy (CAP) support systems were in place throughout the period, substantial fluctuations in agricultural commodity prices, coupled with significant increases in input costs such as energy and fertilisers, have adversely affected profitability. One of the few options available to counteract these trends was to reduce farm labour overhead costs, either by reducing staff numbers or by increasing the size of the farm enterprise. In either case greater levels of productivity were required, both of the labour force and the equipment operated by it. The expansion of farm enterprises led to the creation of larger farm units, which has resulted in a greater geographic spread of land and associated farming activities. Particularly in the case of arable farming operations, fewer workers were required to use fewer but larger tractors to travel further away from the base farmstead to perform operations. Associated rationalisation of farming enterprises frequently resulted in greater reliance being placed upon the services of specialist agricultural contractors whose tractors, by the very nature of the businesses, have to travel substantial distances to perform their duties. In recent years, the subsidised development of anaerobic digestion plants for renewable energy generation in a number of EU Member States has further increasedDraft the geographic spread of agricultural activities and the associated on- road transport workload of agricultural tractors and trailers. These changing requirements have placed greater emphasis upon the productivity, operator comfort and road transport capabilities of modern agricultural tractors (Scarlett, 2013). These assertions are supported by EU agricultural statistics relating to the period in question. It is noteworthy that just six Member States (France, Germany, Italy, Spain, the United Kingdom and the Netherlands) together generate over 68% of EU-28 total agricultural output (Figure 3.1). These Member States also account for the majority of new agricultural tractor sales in the EU (see Section 3.2). Over the 1997–2013 period the domestic agriculture of these Member States all demonstrated the trends outlined above, namely:

 No. of Agricultural Holdings: Decreased by an average of 36% (Figure 3.2). Italy demonstrated the largest reduction (56%), followed by Germany (47%): Spain and the UK returned the smallest changes (21%).

 Average Farm Size: Increased on average by 32% (Figure 3.3). Italian and German farm size increased by the largest margin (~46%), Spanish farm size by the smallest amount (13%).

 Farm Labour Force: Decreased by an average of 32% (Figure 3.4). Italy demonstrated the largest reduction (54%), followed by the UK (34%): Germany returned the smallest change (20%).

Generally, over the last 20 years, the share of utilised agricultural area within the EU cultivated by smaller farms has decreased and that of larger farms has grown. This change is reflected in the size and/or work capacity of agricultural machinery utilised (see Section 3.3).

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Figure 3.1: Output of EU Member States agricultural industries: Contribution to the EU-28 total (in %) Source: (European Union, 2016)

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Figure 3.2: Change in the number of agricultural holdings in selected EU Member States Source: Analysis of Eurostat database (Eurostat, 2017)

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Figure 3.3: Change in average agricultural holding size (area) in selected EU Member DraftStates Source: Analysis of Eurostat database (Eurostat, 2017)

Figure 3.4: Change in the size of the farm labour force in selected EU Member States. (AWU = Agricultural Work Unit = the work of one full-time employee) Source: Analysis of Eurostat database (Eurostat, 2017)

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3.2 The rationale for increased speed Modern agriculture is very firmly run as a business and so it can be safely assumed that the purchase of an agricultural vehicle is in most instances economically rational. Thus, the changes described above in farming will create a different set of requirements that a farmer might have for their machine. That is to say, a fast agricultural vehicle purchase will in most cases be motivated by an economic benefit brought about because of the higher speed and not because, for example, the driver is a thrill seeker who likes to drive fast. A full economic analysis of agricultural transport operations is beyond the scope of this research. However, some existing research evidence exists that allows a simplistic illustration of the order of magnitude of the potential effect that increased tractor speed can have on the economics of farming. This should not be taken as a robust quantification, merely an indication of the order of magnitude and the type of information that would be required if it was considered beneficial to undertake a robust analysis at some future time. It is generally accepted that the quantity of road transport undertaken with agricultural vehicles is increasing. (Gotz, Holzer, Winkler, Bernhardt, & Engelhardt, 2011) cited examples of the reason for such growth as including increasing size of individual agricultural businesses, centralisation of processes, closing of sugar beet refineries and increasing demand for biogas. (European Union, 2016) showed that the average farm size increased from 12.6 ha to 16.1 ha between 2007 and 2013. (Gotz, Zimmerman, Engelhardt, & Draft Bernhardt, 2014) also cited increasing productivity in terms of tonnes of product per hectare of field and an increased utilisation area per active farm. However, the distances that goods are moved within agriculture are relatively short, though growing. Many operations will transport goods from field to farm which can be a very short distance up to around 20-30 km (Gotz, Zimmerman, Engelhardt, & Bernhardt, 2014). Where markets are national or international, those products may well be taken from farm to market in a road-going HGV because the distances are large and HGVs are more fuel efficient. Thus, the additional costs of transhipping goods from the tractor to an HGV are reversed by the reduction in the onward transport costs. If the product is stored at the farm for any length of time then there is no additional trans-shipment cost of loading onto a specialist transport vehicle (HGV). However, in more local or more specialist operations (e.g. biomass, sugar beet, etc.) the farmer may transport products direct from field to market and the distances involved in this can be longer. (Gotz, Zimmerman, Engelhardt, & Bernhardt, 2014) cites distances to sugar beet refineries of up to around 100 km. In Germany, the distribution of freight transport in agriculture is compared to standard road, rail and barge freight in Figure 3.5. Although only a relatively small fraction of all road freight traffic (1.2% of tonne kms), agricultural transport is still significant at 5 billion tonne kms in a year. Dividing the total freight traffic (tonne kms) by the total freight lifted (tonnes) shows that the average length of haul is short at just under 12 km. Unfortunately, no information was presented on the total vehicle kms and there was no information on the average load per vehicle so it cannot be calculated from the data that was presented. If the average load per vehicle was 5 tonnes then there would have been 1 billion vehicle kms by agricultural vehicles. If it was 10 tonnes then there would only have been around 0.5 billion vehicle kms by agricultural vehicles. (Gotz, Zimmerman, Engelhardt, & Bernhardt, 2014) tested a range of different vehicles on a real road route containing a mixture of different urban and rural road types that they considered representative of an agricultural transport operation in Germany. The vehicles were two agricultural tractors (one 121 kW and Vmax of 40 km/h, the other 243 kW and Vmax 50 km/h) a Unimog (210 kW and Vmax of 80 km/h) and a standard articulated truck (310 kW and Vmax of 90 km/h). All but the truck was tested with an agricultural trailer and a semi-trailer. The results for average speeds achieved are shown in Figure 3.6.

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

3209

Transport quantity (million t) Traffic performance (billion tkm)

398 428 341 235 5 92 64

Road Haulage Agriculture Rail Barge

Figure 3.5: Inland goods transport volumes in Germany Source: (Gotz, Zimmerman, Engelhardt, & Bernhardt, 2014)

Series2 Series1

27.03 DraftTruck 45.02 24.37 Unimog semitrailer 42.29 25.15 Unimog agricultural trailer 40.93 24.82 Tractor (243 kW) semitrailer 39.02 26.69 Tractor (243 kW) agricultural trailer 39.00 22.54 Tractor (121 kW) semitrailer 32.54 22.99 Tractor (121 kW) agricultural trailer 33.21

0 10 20 30 40 50

Figure 3.6: Average speeds achieved by different test vehicles in public road trials of different vehicles on a route designed to be representative of German agricultural transport operations.

It can be seen that the increases in average speed were of course less than the increases in maximum speed, likely reflecting the fact that other factors than Vmax constrain the actual travel speed. This can also be seen in the fact that urban speeds were lower than rural speeds (likely a consequence of lower speed limits and increased traffic congestion in many urban areas) and also that the difference between vehicles was less (also contributed to by engine power considerations with increased frequency of acceleration/deceleration cycles). The data was also presented separated by whether the vehicle was full or empty but averaged across both road types. Based on this data increasing the maximum speed of an agricultural tractor from 40 km/h to 50 km/h (with

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h associated power increase) raised average speed from 29.33 km/h to 35.39 km/h (21%) when empty and from 26.88 km/h to 30.01 km/h (12%) when fully loaded. (Mederle, Urban, Fischer, Hufnagel, & Bernhardt, 2015) undertook similar tests on different vehicles with a different route with the aim of optimising standard tractors for transport. They found that increasing the maximum speed from 50 km/h to 60 km/h resulted in time savings of 8.5%. So, in terms of the average 12 km trip then the time taken can be calculated. When combined with labour costs per hour (c €16/h taken from (DfT, 2015) representing UK levels in 2015) the cost saving per trip can be calculated. Similarly, for Germany it is possible to give a crude estimate of the total vehicle kms travelled in agricultural transport (based on a crude estimate of an average load of between 5 and 10 tonnes and data presented by (Gotz, Zimmerman, Engelhardt, & Bernhardt, 2014)). This can be converted to travel times and labour cost savings. The results are shown in Figure 3.1.

Table 3.1: Speeds, travel times and costs for different agricultural vehicle trip scenarios

Average Distance Max Speed Travel time Travel cost Scenario speed (km) (km/h) (hours) (€) (km/h)1 Baseline 12 40 26.88 0.45 7.2 Single vehicle trip High speed 12 50 30.01 0.40 6.4 DifferenceDraft 0 10 3.13 -0.05 -0.8 Baseline 0.5billion 40 26.88 18.6m 297.6m

Estimated High speed 0.5 billion 50 30.01 16.7m 266.6m annual Difference 0 10 3.13 -1.9m -31m agriculture transport in Baseline 1billion 40 26.88 37.2m 595.2m Germany High speed 1billion 50 30.01 33.4m 533.2m Difference 0 10 3.13 -3.8m -62m

No easily available data quantifying the road transport vehicle kms by agricultural vehicles across Europe has been identified. It is not, therefore possible at this time to do a reliable analysis of the likely cost savings for the EU as a whole. However, as a crude proxy measure, (European Union, 2016) shows that agricultural output in Germany was approximately 12% of that of the whole EU in 2015. If agricultural vehicle kms on the road was assumed to correlate with overall output, then the labour saving as a result of reduced travel time by increasing maximum speed from 40 to 50 km/h is up to between around €258million and €516m2. Offsetting this benefit, there would be an increase in fuel consumption. This has not been quantified at this time because the analysis is only a simplistic indication of effects. Consideration of variable fuel cost and machine efficiency add substantially to the complexity of the issue. Additionally, the fact that, where available, tractors capable of exceeding 40 km/h are becoming much more popular, shows that the benefits of the increase substantially outweigh the direct perceived cost to the end-user.

1 Note, average speeds are those for the fully loaded case so likely to be conservative in practice. 2 The wide range of values relates principally to the need to assume a range of likely average loads carried because this data was required for the analysis but unavailable.

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

3.3 The EU agricultural vehicle fleet

The primary focus of this investigation is agricultural vehicles of 40 < Vmax ≤ 60 km/h. In most supply industries, development of the product occurs over time in response to customer / market demand, whether this be predicted or demonstrated. Manufacturers of premium products tend to lead the field with the introduction of new features; others follow once a clear market demand is evident. These trends apply to most products, be they cars, trucks, lawnmowers, vacuum cleaners or agricultural tractors and trailers. Consequently the composition of the EU agricultural vehicle fleet reflects changes in agricultural requirements. The change in fleet composition over time is progressive, as new machines replace older versions. However, it is important to appreciate that whilst older vehicles may be retained within the fleet for back-up / reserve purposes, due in part to the unpredictability and weather-dependency of farming operations, it is the newer ‘frontline’ machines (e.g. ≤ 15 years old) which perform the majority of the work. The following Sections (3.3.1 & 3.3.2) consider EU agricultural vehicle fleet composition, particularly regarding those types deemed likely to travel on-road at higher speeds (T1b, R3b, R4b & S2b) and therefore perhaps benefit most from adoption of ABS technology.

3.3.1 Category T1 wheeled tractors As stated in Section 3.1, changes in EU farm structure have placed greater emphasis upon the productivity of agricultural tractors. Whilst some may suggest that tractors spend the majorityDraft of their operating hours in-field, it is a widely-acknowledged fact that transport activities and (depending upon farm business structure) travel between the farmstead and field make up a substantial proportion of total operating time (Gotz, Holzer, Winkler, Bernhardt, & Engelhardt, 2011). The provision of tractors with greater maximum speed capability has long been recognised as a means of reducing the proportion of unproductive time spent travelling between fields and also improving overall efficiency during material transport operations. Reviewing European tractor development, in the mid-1980s the majority of tractors were of Vmax ≤ 30 km/h capability: by the mid-1990s Vmax = 40 km/h tractors were widely available and by the mid-2000s Vmax = 50 km/h tractors were available from the majority of global manufacturers. Given this progressive increase in tractor maximum design speed capability over a relatively limited time, it appears reasonable to conclude that a significant market demand exists for such vehicles from farmers and agricultural contractors. Given that such higher speed capability is only of benefit during on-road transport and general travel activities, these must represent a significant proportion of overall vehicle use (at least a sufficient proportion of usage to justify the purchase of a tractor with higher Vmax capability).

With the notable exception of the Mercedes-Benz Unimog, Vmax > 40 km/h tractors became available from specialist and premium brand manufacturers (JCB and Fendt) in the early 1990s. As market demand developed, global T1 tractor manufacturers released Vmax = 50 km/h models across their ≥ 100 hp / 75 kW model ranges by 2003 - 2006. Today two manufacturers (Fendt and SDF) offer Vmax = 60 km/h versions of certain (higher-power) T1 tractor models, in addition to Vmax = 40 km/h or 50 km/h variants; one manufacturer (JCB) offers Vmax > 60 km/h vehicles, but of more specialist designs (Figure 3.7). As commented in Section 2.3.1, at present Vmax > 40 km/h capability is generally only offered on T1 tractor models of > 130 hp / > 97 kW rated engine power (Table 2.1).

Vmax = 50 km/h remains the most popular and widely available Vmax > 40 km/h version of T1 ‘conventional’ tractors, being offered as a customer-specified option on ‘standard’

Vmax = 40 km/h vehicles. Some early Vmax = 50 km/h tractors were fitted with higher capacity service braking systems but, for sake of product-build commonality, such capability is often now fitted to Vmax = 40 km/h vehicles. For reasons of both driver comfort and practical drivability on uneven rural roads, Vmax > 40 km/h tractors require suspension on at least one axle (usually the front); the national legislation of some

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

Member States mandates this requirement (see Section 3.4). However, the benefits of front axle and driver cab suspension are now widely appreciated in the marketplace and so are regularly specified by the customer, irrespective of vehicle Vmax capability.

Figure 3.7: Fendt 900 Vario series Vmax ≤ 60 km/h T1 tractor (left) and JCB Fastrac 8000 series Vmax ≤ 70 km/h T1 tractor (right) (Copyright AGCO GmbH & JCB)

It is important to appreciate that, with the widespread introduction of electronic engine and transmissionDraft control systems on modern tractors, the former in response to engine exhaust emissions requirements, the option of Vmax = 40 km/h or Vmax = 50 km/h on a T1 tractor may frequently be selected by configuration of the vehicle’s control software, potentially post-production. This is particularly the case given the increasing availability / popularity of electronically-controlled continuously-variable transmissions (CVTs) upon higher-powered tractors. These transmissions can offer a very wide range of input : output speed ratios and consequently high Vmax capability, if so configured.

Despite the widespread availability of Vmax > 40 km/h T1 tractors since 2003-2006 (depending upon rated engine power), not all EU Member States permit the sale and/or the use of such vehicles at their maximum speed (see Section 3.4). Additionally, whilst new tractors sales in individual Member States are normally recorded, these tend to be categorised on the basis of engine power output and Vmax capability is not always recorded; fortunately there are some exceptions (e.g. Germany (Kraftfahrt-Bundesamt, 2016)). Consequently, in order to gain a reliable insight into the presence and usage of Vmax > 40 km/h tractors in the EU, it has been necessary to compile data from multiple sources and also to make certain assumptions / estimations.

As previously stated (Section 2.3.1), Vmax > 40 km/h capability is generally only offered on T1 tractor models of > 130 hp / > 97 kW rated engine power (Table 2.1), this primarily being due to the minimum level of engine power required for effective tractor- trailer transport operations at speeds above 40 km/h. Whilst certain manufacturers have marketed Vmax > 40 km/h tractors from the early 1990s, such vehicles have been widely produced by all major T1 manufacturers since 2003-2006. Also, just six Member States (France, Germany, Italy, Spain, the United Kingdom and the Netherlands) together generate over 68% of EU-28 total agricultural output (Figure 3.1) and between them account for a similar proportion of new tractor sales in the EU. It is therefore appropriate to consider the vehicle fleets in these Member States in greater detail, from 2006 to the present day, a period over which (if permitted by national legislation) Vmax > 40 km/h tractors would potentially have been available in those countries. Over the 2006–2016 period sales of new > 50 hp (37 kW) tractors in the six selected EU Member States declined, on average, by ~18%. However, over the same period, sales of > 125 hp (93 kW) tractors increased by 35% (Figure 3.8) and sales of > 150 hp (112 kW) tractors increased by ~52% (Figure 3.9). It is noteworthy that in

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

2016 > 125 hp (93 kW) machines accounted for ≥ 60% of new tractor sales in Germany, the UK and the Netherlands. Consequently, it would appear that over the 2006-2016 period, in an otherwise declining market, increasing numbers of more powerful tractors were sold. This corroborates the statements made earlier regarding the rationalisation of EU farm businesses (see Section 3.1). It would appear that, particularly in these Member States, fewer farm holdings of increased size are utilising fewer, larger tractors operated by a reduced labour force. This cannot fail to increase on-road travel distances for individual vehicles.

Draft

Figure 3.8: Proportion of new tractors of > 125 hp / 93 kW rated engine power sold in selected EU Member States over the 2006 – 2016 period Source: AEA data

Figure 3.9: Proportion of new tractors of > 150 hp / 112 kW rated engine power sold in selected EU Member States over the 2006 – 16 period Source: AEA data

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

Whilst these tractor sales data present reliable information showing a distinct increase in the population of annual tractor sales which could be of Vmax > 40 km/h capability, it does not quantify the proportion of vehicles with such capability. Industry stakeholders (CEMA) estimate that approx. 17,000 tractors of 40 < Vmax ≤ 60 km/h capability were sold in the EU during 2016 and that these represented approximately 10% of total EU tractor sales, suggesting a total of approximately ~170,000 vehicles for that year. However, (Jorgensen & Persson, 2013) reported an EU agricultural tractor market of 150,000 in 2011 and it is known that market volumes declined between 2011 and 2016. Other stakeholders suggest that EU total new tractor sales (> 50 hp) in 2016 were more likely to be in the range 125,000 – 135,000 units, as CEMA statistics may have included several non-EU European countries, such as Turkey. If this is the case, 40 < Vmax ≤ 60 km/h tractors would potentially have represented ~13% of the total EU market in 2016; still hardly a large proportion. However, at present not all Member States permit the sale of such vehicles (see Section 3.4) and also this value makes no allowance for the number of vehicles sold in preceding years. Fortunately the German authorities (Kraftfahrt-Bundesamt, 2016) do record both the engine power ratings and Vmax capability of new tractors sold. It would appear that 40 < Vmax ≤ 60 km/h tractors currently comprise ~6% of the German tractor fleet (Figure 3.15), which is not a large proportion. However, during the 2010-2015 period, the number of these vehicles increased by over 23,000 units or by ~42% to approximately 79,000 units, representing ~40% of the German > 90 kW tractor fleet. Arguably this is a significant value. Taking the UKDraft market as an example (one of the six example Member States considered), agricultural tractors of up to Vmax = 40 mph (64 km/h) may be placed on the market, but if driven / used on-road at speeds exceeding 25 mph / 40 km/h they must comply with more stringent constructional requirements, including greater braking system performance (including ABS) and the provision of front and rear axle suspension. However, as the UK does not implement a formal national type-approval scheme, but rather relies upon enforcement of regulations whilst vehicles are in-use, Category T1 tractors of Vmax > 40 km/h capability and ‘conventional’ construction (front axle suspension only and no ABS installed) have found a ready market in the UK. A recent survey of UK agricultural contractors (NAAC, 2017) highlighted the degree of Vmax > 40 km/h tractor operation by this type of user (Figure 3.10). Tractors in the ‘Lower Middleweight’ (151-230 hp) power range were the most numerous, followed by vehicles in the ‘Upper Middleweight (231-320 hp) range; the proportion of these tractors with Vmax > 40 km/h capability was ~85% and ~89% respectively. Perhaps surprisingly, an even greater proportion (100%) of 321-400 hp ‘Heavyweight’ tractors had Vmax > 40 km/h capability, highlighting the importance to this user group, for what may be regarded as an in-field, heavy-draught operations tractor, to be able to travel quickly on-road between jobs. The survey asked UK agricultural contractors to estimate the proportion of time their various-sized tractors spent whilst engaged in the following basic operations:

 In-Field Work: e.g. cultivations, material application, crop harvesting.

 Material Transport: e.g. transport of crop / other materials to/from the field and/or the farmstead / elsewhere.

 General Travel to/from the Field: Not involving transport of consumable materials.

Additionally, the times spent by each tractor size range during ‘Material Transport’ and ‘General Travel’ operations were summed to create a ‘Total Travel’ category which potentially estimates the total time a tractor may spend travelling. It should of course be

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h emphasized that a proportion of ‘Material Transport’ activities will be undertaken in-field as opposed to on-road, but nonetheless these may well be at speeds above 20 km/h.

Draft

Figure 3.10: Power distribution and Vmax capability of tractors currently operated by UK agricultural contractors Source: (NAAC, 2017)

Figure 3.11: Breakdown of tractor time utilisation by UK agricultural contractors Source: (NAAC, 2017)

It would appear that, of all the tractor size categories, vehicles in the 151-230 hp and 230-320 hp ranges perform the largest proportion of ‘Material Transport’ operations (31-32%: see Figure 3.11) and, perhaps understandably, > 320 hp tractors undertake

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h the least (~3%). However, it was estimated that these large tractors still spend ~13% of their time engaged in ‘General Travel’, no doubt reflecting the distances these vehicles are required to travel for agricultural contracting businesses in order to perform their (primary) in-field tasks (~83%). This was however in stark contrast to tractors of 151-230 hp and 230-320 hp, which were estimated to spend 50% and 47% of their total operating time, respectively, engaged either in ‘Material Transport’ or ‘General Travel’: hardly a small proportion. Agricultural contractors are known to be intensive users of the machinery at their disposal. The survey found that vehicles of > 150 hp were, on average, worked for 1200 – 1500 hours per year and were replaced approximately every 5 years. Such contracting businesses are also highly likely to operate over larger geographic areas than normal farms and so, potentially, would be more likely to purchase Vmax > 40 km/h tractors. Draft

Figure 3.12: Breakdown (by engine power) of proportion of new Vmax ≤ 40 km/h and Vmax = 50 km/h T1 tractors sold by a major East Anglian (UK) tractor dealer during the 2013 – 17 period Source: Anonymous UK tractor dealer

However, the tractor sales data of a typical UK main franchised dealer suggests that the penetration of Vmax > 40 km/h tractors into the UK market is very substantial and is equally due to purchases by normal farmers rather than just by agricultural contractors. T1 tractor sales averaged over the 2013 – 2017 period show a very high proportion (~88-89%) of Vmax = 50 km/h vehicles sold in the 151-230 hp and 230-320 hp power ranges and over 70% in the 125-150 hp and > 320 hp ranges (Figure 3.12). Analysis of vehicle sales over time (Figure 3.13) shows a steady increase in sales of Vmax = 50 km/h tractors in all categories above 100 hp / 75 kW to the extent that, for wheeled tractors above 150 hp / 112 kW engine power, Vmax = 50 km/h is almost the default customer choice. This is compelling data, but it can be argued with some justification that the UK is but one market within the EU-28 and that, at present, many Member States do not accept Vmax > 40 km/h tractors (see Section 3.4). It also relates only to sales on new vehicles and, unlike the German data presented in Figure 3.15, it does not indicate the proportion of vehicles in the total UK fleet.

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

Figure 3.13: Variation of Vmax ≤ 40 km/h and Vmax = 50 km/h new tractor sales by a majorDraft East Anglian (UK) tractor dealer during the 2012 – 17 period Source: Anonymous UK tractor dealer

Figure 3.14: Proportion Vmax > 40 km/h T1 tractors produced during 2016 by two global tractor manufacturers Source: Anonymous tractor manufacturers

The recent Vmax > 40 km/h tractor production data of two major global manufacturers potentially provides a more reliable indication of the current situation across the entire EU (Figure 3.14). As previously discussed, the EU-wide demand for Vmax > 40 km/h tractors is without question dependent upon vehicle power, not only because such

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

capability is not readily available on < 130 hp (< 97 kW) machines, but also because higher tractor power : mass ratios are required for effective performance during higher- speed transport operations. Figure 3.14 indicates that ≥ 50% of tractor production from these particular manufacturers in the important, farm transport-orientated 151-230 hp and 230-320 hp power ranges would appear to be of Vmax > 40 km/h capability. Given the final implementation of Regulation (EU) No 167/2013 (European Union, 2013) in January 2018, from which date all Member States cannot refuse the sale / registration of Vmax > 40 km/h tractors (although they can prohibit their higher-speed use - see Section 3.4), it would be surprising if the sales proportions of such vehicles across the EU did not increase in the future.

Draft

Figure 3.15: Variation in the population of 40 < Vmax ≤ 60 km/h tractors in the German agricultural tractor fleet during the 2010 – 15 period Source: (Kraftfahrt-Bundesamt, 2016)

However, the Vmax > 40 km/h tractor data presented for the UK in Figure 3.11 and Figure 3.12 only relates to new vehicle sales. In order to analyse the possible effects of Vmax > 40 km/h tractor operation upon road accident numbers in the UK, this being considered to be a market with high Vmax > 40 km/h penetration and one for which detailed accident data was available (see Section 4), it was necessary to estimate the proportion of such vehicles currently present in the UK tractor fleet and also how this population has changed over time since their first widespread release onto the market (2003-2006). Vehicle registration data was obtained, which specified the number and historical age breakdown of agricultural tractors in use in the UK over the period in question. These data were segregated for each year (on the basis of historical sales vs. engine power data) to reflect the proportion of registered vehicles in each of three major power (100- 200 hp, 200-300 hp & 300-400 hp) present in the total tractor fleet. These data were then factored by the proportion of vehicles sold in each year (in each power band), which were deemed likely to have Vmax > 40 km/h. This was considered to be ~1% prior to 2003-2006 (depending upon the power band), increasing progressively to the proportions indicated by Figure 3.13 for recent years. By this method the total number of

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

Vmax > 40 km/h tractors currently present in the UK fleet was reliably estimated, both as a proportion of the total tractor fleet and also of the vehicles of less than 20 years age, the latter being deemed to reflect tractors which are still likely to be in intensive / frontline use upon farms. Figure 3.16 shows the estimated variation of these vehicle populations to the present time.

Draft

Figure 3.16: Estimated increase in the proportion of 40 < Vmax ≤ 60 km/h tractors in UK agricultural tractor fleet

3.3.2 Agricultural trailers and interchangeable towed equipment As highlighted at the beginning of this section, the primary focus of this investigation is agricultural vehicles of 40 < Vmax ≤ 60 km/h. In practice, agricultural trailers and interchangeable towed equipment are not able to control the speed at which they are operated; they travel at the speed of the vehicle which is towing them. Whilst design- speed or maximum operating speed-related national regulations / requirements do exist in some EU Member States, the implementation of Regulation (EU) No 167/2013 has provided the first route by which agricultural trailers and interchangeable towed equipment may be granted EU type-approval. Additionally, for the first time, this regulation introduces the concept of such vehicles being recognised as suitable for > 40 km/h operation on an EU-wide basis. However, with regard to the timing of this investigation, Regulation (EU) No 167/2013 is still in its first implementation period (2016–2018) and few Category R or S vehicles have yet to receive type-approval, let alone be placed on the market in significant numbers to influence the nature of the EU vehicle fleet. Additionally, as highlighted in Section 2.3, EU type-approval of Category R and S vehicles is not a mandatory requirement of Regulation (EU) No 167/2013. Vehicle manufacturers may instead choose to comply with the relevant national regulatory requirements of individual Member States for the foreseeable future. In time, these national requirements may possibly tend to become aligned with those of Regulation (EU) No 167/2013, but this is as yet uncertain. For these reasons, this investigation has largely viewed the EU trailed agricultural vehicle fleet as it is controlled by current national requirements as opposed to harmonised EU legislation.

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

As highlighted in Section 2.3, this investigation has focussed upon Category R3, R4 and S2 trailed agricultural vehicles, namely those of MPMaxles > 3500 kg. Additionally, as explained in Section 2.3.7, if the ratio of Laden : Unladen mass of trailed equipment (i.e. Category S vehicles) is ≥ 3.0, it is classified as a Category R vehicle; consequently, Category R3 and R4 vehicles are of primary importance. However, if these vehicles are towed by agricultural tractors (assumed to be the case during normal agricultural operations), they are only likely to be used above 40 km/h if the towing vehicle is of > 130 hp / 97 kW engine power, simply because (i) extremely few Vmax > 40 km/h tractors exist below this power level and (ii) these and higher engine power levels are a practical pre-requisite for effective tractor-trailer transport operations above 40 km/h. Given that the towing vehicle is likely to be > 130 hp / 97 kW and probably even > 150 hp / 112 kW in order to ensure reliable Vmax > 40 km/h operation (see Figure 3.10), it is highly likely that the user will wish to operate a trailer of sufficient carrying capacity to fully-utilise this size of tractor. These predictions are confirmed by data from a recent survey of UK agricultural contractors (NAAC, 2017) which suggests that 10-14 tonne capacity trailers are the most numerous (55%) in the UK fleet, followed by 14-17 tonne capacity vehicles (32%). However, whilst over 70% of 10-14 tonne trailers were considered likely to be operated with Vmax > 40 km/h tractors, almost 100% of trailers of more than 14 tonne capacity were likely to be used above 40 km/h (Figure 3.17). This very much confirms the theory that, in the main, larger capacity trailers tend to be used behind higher-powered tractors capable of Vmax > 40 km/h. Draft

Figure 3.17 Trailers operated by UK agricultural contractors: vehicle size (carrying capacity) distribution and proportion used with Vmax > 40 km/h tractors Source: (NAAC, 2017)

The same survey also demonstrated a change in agricultural trailer size (carrying capacity) over time (Figure 3.18); trailers of ≤ 14 tonnes were generally much older (~5 – 20 years), whereas newer trailers (~0 – 10 years) were mainly of 14.1 – 17 tonnes or larger capacity. This correlates well with information gained from UK trailer manufacturers, who claim that the most popular sizes of monocoque (bulk) trailer currently sold are 16 and 18 tonnes capacity, followed by 14 tonnes, followed

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Study on the availability of anti-lock braking systems for agricultural and forestry vehicles with a maximum design speed between 40 km/h and 60 km/h

by > 20 tonnes. This incidentally is in the face of UK national road legislation which (theoretically) does not permit the use of > 13.5 tonne capacity trailers! In truth, trailer carrying capacity is very much influenced by the holding tank capacity of modern (larger) harvesting machinery, which has developed to such an extent over the last 5-10 years that a 14 tonne capacity vehicle is, in many cases, no longer adequate for efficient materials transport without constraining harvesting output. During harvesting operations it is highly desirable that haulage trailers have sufficient carrying capacity to accommodate one or more complete discharges of the harvesting machine’s holding tank. Combine harvester tank capacity now frequently exceeds ~8 tonnes; sugar beet harvester bunker capacity can exceed ~16 tonnes: hence the need for large capacity trailers. It may be argued that the equipment used by agricultural contractors is not necessarily entirely representative of that operated by normal farmers, the former perhaps being generally larger / of greater capacity. However, as discussed in Section 3.3.1, EU sales statistics of tractors do not support this viewpoint, but rather underline the fact that the agricultural equipment market is moving towards fewer, but larger / higher capacity machines. Agricultural contractors frequently have to operate in the smaller and less accessible fields of smaller-farm customers and so will select adaptable equipment with high potential output. Additionally, in other cases, farmers have expanded their operations to ‘contract-farm’ neighbouring land under rental agreements, thereby improving the economic viability of their businesses. Irrespective of the identity of the purchaser, the requirement for larger, more productive agricultural machinery is the same and it wouldDraft appear to represent an increasing proportion of the market.

Figure 3.18: Trailers operated by UK agricultural contractors: population breakdown by carrying capacity and age Source: (NAAC, 2017)

Regulation (EU) No 167/2013 defines trailer size categories not by carrying capacity, but rather in terms of the sum of the technically-permissible masses per axle (MPMaxles). Given the wide variety of trailer sizes and configurations, this is entirely understandable. However, for Category R3 and R4 trailers of the common, rigid drawbar monocoque-body design (see Section 2.3.6), a reliable correlation exists between MPMaxles and carrying

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capacity. This is further illustrated by Table 3.2, together with the proportion of such (UK contractor-operated) vehicles likely to be used at speeds of > 40 km/h. These data (Figure 3.17 and Figure 3.18) provide a quite convincing insight into likely agricultural trailer usage within the UK, particularly at Vmax > 40 km/h, but what about practices in other EU Member States? It is known that the use of Vmax > 40 km/h tractors is only permitted at present in certain Member States (Germany, Austria, UK, Spain, Finland, Ireland, plus certain others – see Section 3.4). Trailer size is also influenced by national road legislation which, again, is not harmonised throughout the EU. However, it is known that the use of large-capacity (R4-type) rigid drawbar trailers is permitted in Germany, France, Belgium, the Netherlands, Ireland, and in a number of other Member States. In many instances the permitted operating masses of these vehicles are larger than are permitted in the UK. Consequently, whilst the market penetration of Vmax > 40 km/h tractors in some of these countries may not be as great as that in UK at present, the use of larger, heavier trailers is potentially greater. Draft

Figure 3.19: Correlation between MPMaxles and carrying capacity of monocoque (fixed- side) Category R3 and R4 agricultural trailers Source: Manufacturer data

Table 3.2: Tandem and tri-axle (rigid drawbar) trailers used by UK agricultural contractors: correlation between carrying capacity, axle loading and use at > 40 km/h. Source: (NAAC, 2017)

Trailer Carrying Capacity MPMaxles Proportion of trailers used (kg) (kg) at > 40 km/h (%) < 10,000 <11,000 33 10,000 – 14,0000 11,000 – 16,000 71 14,001 – 17,0000 ~16,000 – 20,000 97 17,001 – 20,0000 ~20,000 – 23,650 100 > 20,000 > 23.650 100

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3.4 Existing legislation and policy regarding on-road use of agricultural vehicles

As discussed in Section 3.3, the use of Vmax > 40 km/h agricultural vehicles is far from a new phenomenon in many EU Member States, but most enact their own legislation regarding the maximum operating speeds and masses of vehicles used on-road: agricultural vehicles, whilst sometimes treated favourably, are rarely exempted from such requirements. Prior to the introduction of Regulation (EU) No 167/2013, the system of EU whole-vehicle type-approval of agricultural tractors was defined by Directive 2003/37/EC (European Community, 2003), technical requirements and test procedures being specified by a whole range of separate Directives. Directive 2003/37/EC was far-sighted in so much as, in addition to the ‘conventional’ T1, T2 and T3 vehicle categories, it also defined a dedicated category (T5) for Vmax > 40 km/h agricultural tractors. Unfortunately this advantage was never realised in practice because, critically, the technical requirements for T5 tractor type-approval were never entirely finalised and defined (Scarlett, 2015). This effectively meant that, prior to the introduction and implementation of Regulation (EU) No 167/2013 (i.e. 1st Jan 2016), it was not possible to obtain EU type- approval for agricultural tractors of Vmax > 40 km/h.

Until now this issue has posed quite a significant barrier to the use of Vmax > 40 km/h tractors in certain EU Member States. However, as discussed in Section 3.3.1, such tractors have been widely available from all major manufacturers since 2003–2006 and, in a number of cases, up to a decade previously. So prior to the implementation of (EU) No 167/2013, Draftby what means were these vehicles placed on the market? With no EU type-approval route available, tractor manufacturers had no option other than to consider each Member State on a case-by-case basis and, where possible, comply with national legislative requirements, if these permitted or did not preclude the sale of Vmax > 40 km/h tractors. Alternatively national type-approval could be sought for the vehicles in question, if this route existed. A minority of Member States operated national approval schemes for agricultural trailers (particularly larger capacity examples), but > 40 km/h operation of such vehicles was, of course, dependent upon the acceptance of Vmax > 40 km/h tractors in the market. Where the latter was possible, regulations / requirements normally existed to permit the use of Vmax > 40 km/h trailers, subject to enhanced braking and (possibly) suspension system performance requirements.

The influence of specific national requirements for the sale / use of Vmax > 40 km/h tractors have tended to be reflected in the specifications of vehicles offered by global manufacturers in other EU Member States. For instance, Germany is both the largest market for agricultural tractors in the EU-28 and is also a major centre for tractor production. German road regulations permit tractors of Vmax > 40 km/h to be sold / used on-road, subject to a number of requirements, including the installation of front axle suspension, but ABS is not required unless Vmax > 60 km/h. By comparison, the UK permits agricultural tractors of up to Vmax = 40 mph (~65 km/h) to be placed on the market, but if driven / used on-road at speeds exceeding 25 mph / 40 km/h they must comply with more stringent constructional requirements, including greater braking system performance (including ABS) and the provision of front and rear axle suspension. These constructional requirements have not been reflected in the products of global tractor manufacturers, whereas those of the German national market, perhaps understandably, have been. So at the time of writing, the regulation of the EU tractor and agricultural vehicle market is in a state of transition. Regulation (EU) No 167/2013 has defined both vehicle categories and respective technical requirements for the EU type-approval of

Vmax ≤ 40 km/h and Vmax > 40 km/h agricultural vehicles, including both trailers and interchangeable towed equipment. Critically, following the 1st January 2018 implementation date of the regulation for existing types (as opposed to new types) of vehicle, no Member State can prohibit the placing on the market, the registration or the entry into service of vehicles which comply with the requirements of the regulation. Essentially this means that, importantly, EU Member States which previously refused to

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accept Vmax > 40 km/h agricultural vehicles will no longer be able to do so if the said vehicles have been type-approved in accordance with the requirements of Regulation (EU) No 167/2013.

Theoretically this could lead to a significant increase in the market for Vmax > 40 km/h agricultural vehicles. Individual Member States will, of course, still be entitled to limit the speed of use of such vehicles by means of national speed restrictions enforced by the Police and other enforcement methods. However, it is not permitted for the specification / construction or the performance of the vehicle to be modified or restricted following type-approval. Subject to the existence and degree of enforcement of any such national speed restrictions, it is therefore highly probable that such vehicles will be regularly used at their maximum design speed, where vehicle power : weight ratio and the mass of any attached trailer permits. Indeed, in certain countries where the use of Vmax ≥ 40 km/h tractors is currently permitted, in appropriate road conditions, operation at higher forward speeds is considered to cause less delay and frustration to other road users and reduce the likelihood of dangerous overtaking manoeuvres by them, thereby actually reducing overall accident risk. However, no evidence exists to support this view. It is also appropriate to highlight that some Member States impose periodic roadworthiness assessment (testing) requirements on agricultural tractors and trailers used at speeds above 40 km/h. Austria is known to operate such a system, whereas it is believed certain other Member States (e.g. Germany) are considering doing so. Directive 2014/45/EU (European Union, 2014) specifies these requirements, but permits individual Member States to exempt agricultural and forestry vehicles from the requirements ifDraft they consider it appropriate. As commented in Section 1.2, this investigation went to considerable lengths to survey the National Approval Authorities, Enforcement Authorities, Technical Services and (with the further assistance of the European Commission) the National Transport Authorities of EU Member States, to identify current and forthcoming (post-January 2018) national requirements for the operation of Vmax > 40 km/h agricultural vehicles. Unfortunately, the overall response received was low. The following tabular summaries of the national requirements of Member States have therefore been compiled with the information which is currently at our disposal and are not deemed to be either exhaustive or error-free.

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Table 3.3: Current national transport policies of EU Member States regarding the on-road use of Vmax > 40 km/h agricultural vehicles (where known)

> 40 km/h operation Member permitted Conditions / requirements for sale and/or use State > 40 km/h Tractor Trailer

Vmax ≤ 60 km/h tractors permitted (if fitted with front Germany Yes Yes axle suspension). ABS braking system only required if Vmax > 60 km/h France No No Operation > 40 km/h not permitted Italy No No Operation > 40 km/h not permitted Solo tractors may operate between 40 – 70 km/h, Spain Yes No depending upon specification, but are restricted to ≤ 25 km/h if towing a trailer Tractors must feature enhanced braking systems Yes (UNECE Reg 13 or 71/320/EEC-compliant) and ABS, United (≤ 65 Yes front & rear axle suspension plus other requirements. Kingdom km/h) Vmax > 40 km/h trailers must comply with Category O vehicle requirements.

Vmax ≤ 25 km/h has been mentioned, but others Netherlands Unclear Unclear suggest Vmax > 40 km/h may be permitted under Draftcertain national regulations Vmax ≤ 50 km/h tractors permitted (if fitted with front Yes Yes axle suspension). ABS system required > 50 km/h. Austria (≤ 50 (≤ 50 Vehicles restricted to agricultural and forestry uses. km/h) km/h) Vmax > 40 km/h trailers must comply with Category O vehicle requirements (Directive 2007/46/EC, Annex IV)

Vmax > 40 km/h tractors must be plated & meet higher braking performance requirements ABS required if Republic of V > 60 km/h. Similar speed-related requirements Yes Yes max Ireland for trailers plus suspension & minimum tyre size stipulations. Vmax > 40 km/h trailers must be fitted with pneumatic braking systems Belgium No No - Denmark No No - Yes Yes Finland (≤ 50 (≤ 50 Precise requirements not known km/h) km/h) Sweden No No - Portugal No No - Information suggests V > 40 km/h operation may be Poland Unclear Unclear max permitted under certain national regulations Czech Information suggests V > 40 km/h operation may be Unclear Unclear max Republic permitted under certain national regulations Hungary No No - Information suggests V > 40 km/h operation may be Bulgaria Unclear Unclear max permitted under certain national regulations Information suggests V > 40 km/h operation may be Romania Unclear Unclear max permitted under certain national regulations Yes (No Yes (No Vehicles must comply with general road traffic rules Latvia upper limit) upper limit) including posted speed limits

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Table 3.4: Likely future national transport policies of EU Member States (post-Regulation (EU) No 167/2013 implementation) regarding the on-road use of Vmax > 40 km/h agricultural vehicles (where known)

> 40 km/h operation Conditions / requirements for sale and/or use Member permitted > 40 km/h State Tractor Trailer National requirements largely unchanged: already in Germany Yes Yes agreement with category ‘b’ requirements of (EU) No 167/2013 & associated Delegated Acts France No No Operation > 40 km/h will not permitted Italy No No Operation > 40 km/h will not permitted Spain Yes No Unclear National requirements largely unchanged: already in United Yes Yes general agreement with category ‘b’ requirements of Kingdom (≤ 65 km/h) (EU) No 167/2013 & associated Delegated Acts Vehicles must comply with category ‘b’ requirements of Netherlands Unclear Unclear (EU) No 167/2013 & associated Delegated Acts, but national speed limitations may be imposed Tractors and trailers must comply with category ‘b’ Austria Yes Yes requirements of (EU) No 167/2013 & associated DraftDelegated Acts

Vmax > 40 km/h tractors must be plated & meet higher braking performance requirements ABS required if Vmax > 60 km/h. Similar speed-related requirements Republic of for trailers plus suspension & minimum tyre size Yes Yes Ireland stipulations. Vmax > 40 km/h trailers must be fitted with pneumatic braking systems. Assume compliance with (EU) No 167/2013 category ‘b’ requirements will also be deemed acceptable Belgium No No - Denmark Unknown Unknown - Yes Yes (≤ 50 km/h, (≤ 50 km/h, Precise requirements not known, but harmonisation Finland but possibly but possibly with (EU) No 167/2013 category ‘b’ requirements likely higher) higher) Sweden Unknown Unknown - Portugal No No - Information suggests V > 40 km/h operation may be Poland Unclear Unclear max permitted under certain national regulations Czech Information suggests V > 40 km/h operation may be Unclear Unclear max Republic permitted under certain national regulations Hungary No No - Bulgaria Unknown Unknown - Romania Unknown Unknown - Yes (No Yes (No Vehicles must comply with general road traffic rules Latvia upper limit) upper limit) including posted speed limits

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4 Accidents related to agricultural vehicles

4.1 Influence of speed on injury risk

4.1.1 Effect on collision frequency Many research studies have examined the relationship between speeds and collision risks. In general, the conclusion is clear, higher speeds increase risk. Historically, agricultural tractors were restricted to very low speeds. However, a wide range of different ways of characterising speeds and different changes to speed have been considered in different studies. The available research is dominated by collisions involving passenger cars with contributions considering the effect of differential speeds for trucks and buses. It is also possible to separately consider the effect of speed on crash frequency or on crash severity (i.e. injury outcome). At this stage, no research has been found directly studying the relationship, if any, between maximum design speed of agricultural tractors and collision risk. (Greenan, Toussaint, Peek-Asa, Rohlman, & Ramirez, 2016) did find (in Iowa, US) that agricultural vehicle collisions were more likely to occur on roads with higher speed limits (≥ 80 km/h) but if it is assumed that the tractor speed capability remained low, this is more likely to be associated with the increased speed of other traffic. When considering the effect of speed on the frequency of collisions, results are often quoted as showingDraft that a 1% change in average speed is associated with a 5% change in accident frequency. However, (Taylor, Lynam, & Baruya, 2001) explored this generic relationship in more detail. They noted that there is a fundamental difference in study approaches; many use a road-based approach examining different measures of speed on a given road or road type and the average crash frequency on that road. Others use a driver-based approach, examining the speed that drivers chose to drive in different circumstances and their personal collision history. In combination, the analyses of (Taylor, Lynam, & Baruya, 2001) found that whatever the study method or speed criteria, there was a strong relationship with collision frequency. However, they found that both increases in average speed and increases in the spread of speeds around the average both separately increased collision frequency and this applied to both urban and high speed rural roads. If the contribution of increasing agricultural tractor speeds to this were considered then, in the absence of other changes, it would increase the average speed on that road by an extent depending on relative density of agricultural vehicle and other traffic, probably a small amount in most cases. However, it would reduce the spread of speed around the average in most cases because it would be likely that agricultural tractors would be at the bottom of the speed range. It was also found that the influence of speed on accident frequency was slightly less (4% compared to an average 5%) on lower speed rural roads and less again (3%) for higher speed rural roads. The concept of the spread of speed around the average has been raised by stakeholders during both the consultations and face-to-face discussions, highlighting that a significant number of agricultural vehicle collisions occur because a higher speed vehicle such as a car or a truck collides with the rear of a much slower moving tractor ahead. It is argued that if this differential speed is reduced, the probability of such collisions will be reduced, as would the severity. (Greenan, Toussaint, Peek-Asa, Rohlman, & Ramirez, 2016) noted this as a possible explanatory variable for a high proportion of rear end crashes where farm equipment was involved in Iowa. However, no scientific study has directly attempted to measure the effect of tractor speed capability on crash frequency. Heavy Goods Vehicles (HGVs) in Europe are typically subjected to differential speed limits. That is, on many higher speed roads, the maximum permitted speed for HGVs will be less than for passenger cars. This could be considered broadly analogous to the differential speeds observed as a consequence of low speed capability, though the

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hypotheses are reversed (improve truck safety by reducing maximum speed, improve tractor safety by increasing maximum speed). (Harkey & Mera, 1994) studied differential car/truck speed limits in the USA and found that overall, they made little difference to safety in terms of either collision frequency or severity. However, they did find that the type of collision sustained might change. Where trucks were restricted to a lower speed than cars, rear end shunt type collisions were more likely to involve a car colliding with the rear of a truck. However, where the speed limit was uniform, all car to truck accidents were more likely to involve trucks striking cars. There was little difference in single vehicle collisions. These overall findings were consistent with (Neeley & Richardson, 2009) who found that increasing the truck speed limit correlated closely with increasing collision rates but that having different speed limits for different vehicle types did not. It was suggested that this finding may have been at least partially because the compliance with differential speed limits was not as good as for uniform limits such that the actual difference in speed between trucks and cars would be less than suggested by the posted limit alone. (Neeley & Richardson, 2009) did also cite other studies that had found a beneficial effect of differential speed limits. When considering how these results might be applied to agricultural vehicle collisions, it is important to note that the distribution of agricultural vehicle traffic by road class will be different to trucks and that the differential speeds reviewed for trucks were in the range of 55-75 mile/h (88-120 km/h). Thus, the speed differential between agricultural vehicles at 40-60 km/h and other traffic will be much greater than for trucks. In addition to this, the differenceDraft relates to the maximum speed capability of tractors, not the posted speed limit. Therefore, the compliance element is much less relevant because drivers of a T1 tractor physically cannot drive it in excess of 40 km/h (in most circumstances). If the vehicle is upgraded to be capable of 60 km/h, then in many jurisdictions there will be no legal impediment to using it to its maximum speed on many road classes. Thus, the difference in actual speeds may be proportionally greater when comparing low speed and high speed tractors than when comparing the actual average speed of trucks (with very similar maximum speeds) in different speed limit regimes. Thus, in summary, there is clear evidence to suggest that increasing average speeds increases collision risk across a range of vehicle types and across all road types. The influence of speed differentials and the spread of speeds around the average allows the possibility that the effect of increasing the speed of low speed agricultural vehicles might be mitigated to some extent by a reduction in differential speed. However, the evidence in respect of this is somewhat ambiguous and difficult to directly transfer to agricultural vehicles. It is possible that it would not mitigate risks overall, merely change the risk from one type to another (for example car front to tractor rear becomes tractor front to car rear).

4.1.2 Effect on collision severity In addition to the potential effect on the probability of becoming involved in a collision in the first place, speed can have an influence on the severity of injury outcome in a collision. Again, evidence related specifically to collisions involving agricultural vehicles is extremely limited, so comparison must be based on theory and evidence from analyses of other vehicle types. With respect to collisions, a range of speeds can be defined:  Travel speed: the speed at which an individual vehicle is travelling immediately prior to the start of the sequence of events leading to a collision. In most cases, this is the speed at the start of emergency avoidance action.  Impact speed: the speed of an individual vehicle at the moment it first makes contact with a collision partner (e.g. another vehicle, pedestrian, or roadside object).

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 Closing speed: the relative speed between a vehicle and its collision partner as they approach impact. If a car travelling 60 km/h approaches the rear of a tractor travelling at 30 km/h in the same direction then the closing speed is 30 km/h. If a car travelling 60 km/h approaches the front of a tractor travelling at 30 km/h in the opposite direction then the closing speed is 90 km/h.  Change in velocity (often known as delta-V): The change in speed experienced by a vehicle during the impact itself. Assuming equal mass and perfect impact conditions, a head on collision between two cars each travelling at 30 km/h would see a closing speed of 60 km/h but a delta-V of 30 km/h. A car to car rear collision where one car had an impact speed of 30 km/h and the other was stationary would see a closing speed of 30 km/h and a delta-V of 15 km/h (that is the impacting vehicle would get closer to the stationary vehicle at a speed of 30 km/h and when it collided with the stationary vehicle both would end up moving at 15 km/h, a deceleration for the impacting vehicle and an acceleration for the vehicle hit from behind). The fundamental property influencing the effect of speed on collision severity is the kinetic energy, which increases in proportion to vehicle mass and the square of speed. Thus, increasing vehicle mass by 50% would increase kinetic energy by 50% but increasing speed by 50%, for example from 40 km/h to 60 km/h would increase kinetic energy by 125%. When considering how injury severity relates to speed, there is a well-documented correlation between severity and the change in velocity (delta-V) experienced during a collision. The Draft relationship varies for different types of crashes. Many such examples of these relationships can be found in the literature; Figure 4.1 shows examples produced by (Richards, 2010). The pedestrian example in Figure 4.1 is the only one that uses the speed of a single car at impact as the measure of risk. This is because the speed of the pedestrian will be low and combined with the very low mass of a pedestrian this makes the influence of pedestrian speed relatively negligible. In the relationships for car occupants, the measure used is ‘delta-V’, the change in velocity experienced by the car the occupant was travelling in. This will depend on the impact speed not only of the vehicle the occupant was travelling in but also the impact speed of the other vehicle that was struck and any difference in mass between the two. In some tractor accidents, for example where they are struck from behind by another vehicle due to the impacting vehicle failing to react appropriately to their low speed, increasing tractor speed would actually reduce the delta-V experienced by both parties in the collision. Thus, the net effect of increased tractor speed on injury severity is not as simple as it may first appear and it will depend strongly on how speed affects the different types of collisions that are prevalent in any individual territory. That is, if collision patterns are substantially different in different member states, then the effect on injury severity of increasing speed in those member states may also differ.

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Car drivers in frontal impacts (all ages, belted, impacts with another car, n = 620)

100% 90% 80% 70% 60% 50% 40% 30% 20% Risk Risk car of driver fatality 10% 0% 0 10 20 30 40 50 60 70 80

Delta-v (mph)

Car drivers in side impacts (all ages, belted, impacts with another car, n = 118)

100% 90% 80% Draft70% 60% 50% 40% 30% 20% Risk Risk car of driver fatality 10% 0% 0 10 20 30 40 50 60 70 80

Delta-v (mph)

OTS and Police fatal file data (all ages, front of cars, n = 197)

100% 90% 80% 70% 60% 50% 40% 30% 20%

Risk Risk of pedestrian fatality 10% 0% 0 10 20 30 40 50 60 70

Impact speed (mph)

Figure 4.1: Relationship between delta-v and risk of fatality for car drivers in frontal impacts (top), side impacts (middle) and pedestrians in collision with a car (bottom) [dashed lines indicate statistical confidence limits around the central estimate of probability indicated by the solid blue line] Source: (Richards, 2010)

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4.2 Effect of Mass on Injury Severity It has been shown in the preceding section that the change of velocity seen by each individual party involved in a collision is likely to strongly influence the probability that they will suffer a serious injury as a consequence. For a given set of impact speeds, the difference in mass between a vehicle and its collision partner will strongly affect the change of velocity seen by each vehicle in the crash. For example, if two cars of equal mass collide head on each with an impact speed of 30 km/h, both will be stationary post collision and both will see an equal change in velocity and a nominally equal risk of serious injury to the occupants. However, if a 44-tonne truck collides with a 1.5 tonne car head-on each with an impact speed of 30 km/h, then immediately post-collision the truck will be travelling at around 28 km/h in its original direction of travel (delta-V 2 km/h) and the car will be travelling backwards at a speed of around 28 km/h (delta-V 58 km/h). Thus, the risk of injury for the occupant of the heavy vehicle is reduced and the risk for the occupant of the light vehicle is increased. The probability of serious injury with respect to delta-V is non-linear. Thus, the benefit attributable to mass, to the occupant of the heavy vehicle might be less than the penalty for the occupant of the light vehicle. Thus, in addition to shifting the balance of risk from occupants of tractors to collision partners, the higher mass of tractors compared with most other vehicles also leads to the possibility of more severe outcomes overall. The effect of mass on delta-V is illustrated across a spread of different vehicle mass configurations in Figure 4.2. This shows that the proportion of the closing velocity experienced asDraft a change in velocity by the lighter vehicle increases rapidly when the ratio between vehicle masses is small. For example, a vehicle colliding with another vehicle a little more than double its mass will already see 70% of the closing speed as its change in velocity (with the heavier vehicle experiencing 30% of the closing speed). Once the mass ratio exceeds around 10 to one, then the change in velocity experienced by the lighter vehicle changes relatively little in response to further increases in the mass ratio.

Figure 4.2: Proportion of change of velocity seen by the lighter vehicle as a function of mass ratio between the vehicles Source (FHWA, 2000)

If collisions between vehicles and pedestrians are considered, then the mass ratio is usually well in excess of 10, so differences in mass between vehicles are not particularly significant in the injury risk to the pedestrian. However, if the risk to car occupants in collision with agricultural vehicles is considered, the mass ratio may be significant. The mass of All-Terrain Vehicles (ATVs) and Side-by-Side (SbS) vehicles will be lower than

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the mass of the cars in many instances and in either direction the mass ratio will be relatively small. However, even relatively lightweight solo tractors will be 3 or 4 times heavier than many passenger cars. Passenger cars will usually be in the range of 1 tonne to 3 tonnes. The 10 to 1 weight ratio where further increases in mass have little effect on injury risk is therefore between around 10 tonnes and 30 tonnes. Although many factors will influence the severity of collisions, the accident data presented in section 4.3.1 is consistent with this theory showing both that accidents involving agricultural vehicles are more likely to be fatal than other crash types and that the fatalities are more likely to be a collision opponent than an occupant of the agricultural vehicle.

4.3 Review of accident data for all agricultural vehicles

4.3.1 Collision frequency and severity The main source of accident data for Europe is the CARE database (the EC database on road traffic accidents resulting in death or injury; (European Commission, 2017). This is compiled from statistics supplied by the relevant Government departments in each Member State. However, although the standardisation of data has been steadily improving since the database began, differences in the extent of data captured by different Member States and in the way it is coded and categorised means that the detail available can be limited. Considerably more detailed data is available for collisions occurring in Great Britain (GB; i.e. England, Scotland and Wales), from the Stats19 database (i.e. Draftthe database of road traffic accidents reported to the police (Department for Transport (UK), 2016a)). Thus, high level statistics have been produced based on CARE data for the EU as a whole. Data for GB has been compared to that for the EU at a high level to assess the degree to which GB might be considered representative of the EU. Then more detailed analyses have been based mainly on GB analyses, supplemented with detailed evidence from other Member States where available and applicable. In 2015, just over 1.45 million casualties from road traffic collisions in the EU-28 were recorded on the CARE database. Of these, 26,165 (1.8%) were fatally injured. Table 4.1 shows the number of casualties that arose specifically from collisions where at least one agricultural tractor was involved.

Table 4.1: Casualties from EU collisions involving agricultural tractors by injury severity and year. Source: Analysis of CARE database

Number of casualties Years Fatal Serious Slight Unknown Total 2005 563 2053 5324 802 8742 2006 471 1850 4739 789 7849 2007 557 1916 5098 782 8353 2008 449 1698 4660 720 7527 2009 478 1765 4826 695 7764 2010 460 1654 4832 733 7679 2011 441 1651 4677 710 7479 2012 393 1540 4514 686 7133 2013 386 1412 4311 665 6774 2014 404 1515 4515 708 7142 2015 395 1499 4301 547 6742

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It can be seen that in 2015, 395 people were killed in collisions involving agricultural vehicles in the EU. This is a significant number, and one would be one too many. It also represents 5.9% of all those injured in collisions involving agricultural vehicles, a substantially higher fatality rate then for all vehicles (1.8%). It is also slightly higher than the equivalent rate for collisions involving HGVs (5.7% in 2015). However, 395 remains a small proportion of the total road toll in Europe and it can also be seen that the absolute number of casualties from these collisions has typically seen a long term decline, with some evidence of a recent slowing or stagnating of that decline (since 2012), in common with all collision types. A more detailed comparison with all crashes is shown in Figure 4.3.

Draft

Figure 4.3: Casualties from collision involving agricultural vehicles as a proportion of all road casualties in the EU-28 Source: Analysis of CARE Database

Again, this reflects the relatively small proportion of all accidents that involve agricultural vehicle and the fact that when an agricultural vehicle becomes involved in a collision it tends to be more severe than average (~0.4% of slight casualties but ~1.5% of fatalities). However, it can also be seen that as a proportion of the total road casualty problem, slight and serious casualties from collisions involving agricultural vehicles appear to have remained approximately constant but fatalities are representing a substantially growing proportion. Combined with the absolute numbers this shows that fatalities from collision involving agricultural vehicles are falling but they are not falling as fast as in other areas of road transport as a whole. This is true if specifically comparing to collisions involving HGVs (Figure 4.4), probably the closest comparator group in the wider road vehicle fleet. The proportion involving an HGV is much larger because of the greater number and greater distance travelled on the road but the trend over time is a small decline in the proportion of all fatalities that arise from collisions involving an HGV.

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18.0% 16.0% 14.0% 12.0% 10.0% 8.0% 6.0% 4.0% 2.0% 0.0% 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 from a collision froma collision involving an HGV (%) Proportion casualties fo all that arose Year

Fatalities Seriously injured Slightly injured KSI

Figure 4.4: Casualties from collision involving HGVs as a proportion of all road casualties in the EU-28 Source: Analysis of CARE Database

Equivalent dataDraft for agricultural vehicles in Great Britain has been sourced from the Stats19 database (Department for Transport (UK), 2016b). In 2015 there were a total of 1730 fatalities, 22,144 serious injuries and 162,135 slightly injured casualties on GB roads. Data with respect to those collisions that involved at least one agricultural vehicle is reproduced in Table 4.2.

Table 4.2: Casualties from GB collisions involving agricultural tractors by injury severity and year. Source: Analysis of Stats19 database

Number of casualties Years Fatal Serious Slight Unknown Total 2005 37 158 844 1039 37 2006 26 176 752 954 26 2007 34 133 814 981 34 2008 21 139 696 856 21 2009 18 129 629 776 18 2010 22 127 649 798 22 2011 21 126 570 717 21 2012 25 157 655 837 25 2013 23 134 567 724 23 2014 31 118 597 746 31 2015 24 128 491 643 24

In terms of fatalities from agricultural vehicle collisions, Great Britain sustains on average 5.6% of all those occurring in the EU, though in individual years this varies from 3.8% to 7.7%. The proportion of those involved in agricultural vehicle collisions that are killed was on average 3.1%, compared to an average for all GB collisions of (1%) over the whole time period studied. Thus, collisions involving agricultural vehicles in Great Britain

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are considerably more (approximately 3 times more) likely to be fatal than all collisions. The absolute fatality rate (3.1%) is about half of the equivalent value for the EU (5.9%). However, the ratio between the fatality rate for agricultural accidents and all accidents is about the same, at approximately 3, in Great Britain and the EU. Fatality rates depend strongly on the extent of under-reporting of low severity collisions, which is known to vary quite substantially across Europe and is likely to explain this difference. A more detailed comparison of the number of casualties from GB collisions involving agricultural vehicles to all casualties is shown in Figure 4.5.

Draft

Figure 4.5: Casualties from collision involving agricultural vehicles as a proportion of all road casualties in GB Source: Analysis of Stats19 Database

It can be seen that the scale of agricultural vehicle collisions in Great Britain is similar to the EU and that the same trend is observed; fatalities from collisions involving agricultural vehicles appear to be representing a growing proportion of all road fatalities. This trend appears slightly more pronounced in Great Britain than in the EU. Thus, based on these high-level figures and trends, it can be concluded that collisions involving agricultural vehicles represent only a small proportion of the EU road safety problem. However, they are around 3 times more likely to result in fatality than all collisions and there is evidence to suggest that fatalities from collisions involving agricultural vehicles have started to represent an increasing proportion of the fatalities from all collisions. In short, they are much less frequent than crashes involving other vehicles and the absolute number is reducing. However, when they do occur, they are much more severe than average and the frequency of fatalities from agricultural vehicle collisions is reducing more slowly than for other vehicle types such that they represent an increasing proportion of the total. At a high level, GB collisions involving agricultural vehicles are broadly representative of the EU as a whole.

4.3.2 Casualty rates The number of collisions that a particular type of vehicle is involved in will not only depend on the safety performance of that type of vehicle but also the exposure to risk. For example, silver cars will be involved in many more collisions than luminous yellow cars, not because silver cars are less conspicuous or more dangerous in other ways but simply because there are more of them. The most commonly used measure of exposure to risk is the number of kms driven on the public road. However, data on the vehicle kms

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travelled by agricultural vehicles is not available. Data on the number of vehicles registered is often taken as the next best proxy for exposure to risk. Agricultural vehicle registration data has not been identified on a cross EU basis but was available for the UK. It has been combined with the casualty data produced above to derive the casualty rates shown in Figure 4.6.

Draft

Figure 4.6: GB casualty rates per 100,000 registered vehicles for all collisions and collisions involving agricultural vehicles Source: Analysis of Stats19 and DfT licensing data

It can be seen that agricultural vehicles cause casualties at less than half the rate per registered vehicle than all vehicles do, taken as a whole. This appears logical when combined with the anecdotal expectation that agricultural vehicles would do far fewer road kilometres than most other vehicle types, spending a significant amount of operating time off-road etc. It is also worth noting that this rate has declined over the period by 46% for agricultural vehicles compared to only 35% for all vehicles, which will be numerically dominated by passenger cars. However, the outcome is quite different if only fatalities are considered, as shown in Figure 4.7 on the following page. It can be seen that the fatality rate per registered vehicle is actually higher for agricultural vehicles than it is for all vehicle types despite the anecdotal expectation of substantially lower road kilometres driven by agricultural vehicles. In addition to this, the evidence of a decline in the risk presented is much weaker and, if there has been a statistically significant decline then at best it would appear to have ended in 2009 and at worst to have turned to a slight increase since then. The number of vehicles registered is a relatively weak measure of the ‘exposure to risk’ for a given vehicle type. This is because, for example, it takes no account of the distance travelled on the roads. In freight terms, the most important parameter to measure performance is the quantity of goods moved because this is the underlying size of the job that must be done to support the economy, regardless of how many vehicles, or what type of vehicles, are required to achieve it. Goods moved is usually defined as the mass of goods carried multiplied by the distance that they were transported and is, therefore, measured in tonne.kms.

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Draft Figure 4.7: GB fatality rates per 100,000 registered vehicles for all collisions and collisions involving agricultural vehicles Source: Analysis of Stats19 and DfT licensing data

Although these measures are commonly available for heavy goods vehicles they are not typically available in agriculture. However, (Gotz, Zimmerman, Engelhardt, & Bernhardt, 2014) presented comparative data for Germany looking at the freight tasks undertaken by road transport (HGVs) and in agriculture (Tractors). The data is understood to relate to the year 2011 and casualty data for the two groups for that year has been obtained from the CARE database. The results are shown in Table 4.3.

Table 4.3: Casualties, goods moved and casualty rates for agricultural transport and road transport by HGVs in Germany 2011. Sources: (European Commission, 2017) & (Gotz, Zimmerman, Engelhardt, & Bernhardt, 2014)

Fatal Serious Slight Casualties

63 631 1,679

Goods moved (Billion tkm) 5

Vehicles Casualty rate per billion tkm Agricultural 12.6 126.2 335.8

Casualties 564 3850 14499 Goods moved (Billion tkm) 398 HGVs Casualty rate per billion tkm 1.4 9.7 36.4 Ratio of casualty rates (agricultural/HGV) 8.9 13.0 9.2

It can be seen that based on this measure, agricultural vehicles cause casualties and between around 9 and 13 times the rate per unit of goods moved than is the case in normal road freight using HGVs. Many factors will contribute to this, including the fact

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that agricultural vehicles get used on the road for tasks other than freight movement, HGVs travel longer distances, at higher speeds but with a higher proportion of traffic on safer roads such as motorways. However, the relative like for like risk presented by each vehicle will also form part of the net result.

4.3.3 Collisions by road class Agricultural vehicles fulfil a specialist role and are typically banned from using the highest speed highways (motorways in the UK). As such, their exposure to risks will be different to that of other vehicle types. The influence of speed on collision risk (see Section 4.1) and the effectiveness of ABS on heavy goods vehicles (see Section 5.2.3) have both been shown to vary on different classes of road so this variation may be an important consideration. Analysing the EU accident data shows that the distribution of agricultural vehicle collisions by road class is, as expected, different to that of all vehicles as a whole (see Figure 4.8 on the following page). The definition of road types3 used in the Figure is summarised below:  Principal arterial: Motorways or Expressways mainly serving long distance and inter-urban movements.  Secondary arterial road: Connected to principal arterials and serving middle distance movements but not crossing through neighbourhoods.  CollectorDraft: A collector crosses urban areas and collects or distributes traffic to/from local roads and/or to and from arterial roads.  Local: A road used for direct access to various land uses (property, commercial areas etc.) at low service speeds not designed to serve interstate or suburban movements. It can be seen that more than half of agricultural vehicle fatalities occur on secondary arterial roads, compared with 44% for all collisions. As would be expected few occur on primary arterials because there will be very little agricultural traffic on such roads. It is possibly more surprising that there is not much difference between agricultural collisions and all traffic collisions when local roads are considered. However, this may be because there is no split in the definition between urban and rural. It can be seen that the severity of collisions also tends to vary by road class, though much less for agricultural vehicles than for all vehicles. That is, collisions on secondary arterial roads are more likely to prove fatal, representing 24% of all casualties but 44% of all fatalities (46% and 51% when only those involving an agricultural vehicle are considered). This may possibly be linked to the fact that the speed of agricultural vehicles remains relatively low even on more major roads whereas the speed of other vehicles will increase in line with the speed limit on major roads. These complexities are likely to correlate with different usage of agricultural vehicles and highlight the complexity of trying to map findings from other vehicle types to agricultural vehicles.

3 It should be noted that these definitions do not necessarily match those used in contributing member states and the time at which individual member states have been able to supply data in this form has varied. This has meant that for some countries there has been a step change in distribution at a fixed point in time and also that the proportion of ‘unknowns’ is relatively high.

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Slightly injured casualties Fatalities

s Allcollision

Draft

Collisions involving agricultural tractors agricultural involving Collisions Figure 4.8: Distribution of EU collisions by road class Source: Analysis of CARE database

Similar analyses have been undertaken based on GB data with national road class definitions and the story is very similar (Figure 4.9). Motorways and A(M) roads are approximately equivalent to ‘Primary Arterials’ and ‘A’ roads will approximate to secondary arterials. It can be seen that 54% of GB fatalities involving an agricultural vehicle occur on ‘A’ roads.

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Draft

Figure 4.9: Distribution of GB collisions by road class Source: Analysis of Stats19 database, average for years 2005-15

When collisions of lower severity were considered, a slightly smaller proportion occurred on ‘A’ roads. The trend over time was examined to see if the changes in the nature of farming, agricultural vehicle design and use had influenced the distribution of collisions by types of road. The number of fatalities was strongly affected by low number variation and so the results were grouped into killed and seriously injured (KSI) and into major (M, A(M), A) roads and minor (B, C, and U) roads in order to increase statistical power. The results are shown in Figure 4.10 and it can be seen that there is no evidence to suggest a systematic change in pattern, with correlation factors approaching zero.

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Figure 4.10: DistributionDraft of GB KSI casualties from accidents involving one agricultural vehicle by major and minor road over time Source: Analysis of Stats 19 data

4.3.4 Speed capability and collision speeds Neither the maximum speed capability of an agricultural vehicle, nor the actual speed of vehicles at the moment of collision are recorded in the CARE or GB Stats19 databases. Thus, collisions cannot be divided by either measure to specifically identify the number of collisions sustained by agricultural vehicles capable of in excess of 40 km/h or to assess whether the speed was a factor in the collision. It is possible to link GB Stats19 data to registration data containing the make, model and maximum permitted mass of a vehicle. It was thought that this might allow speed capability to be inferred from this proxy information. However, when the analysis was attempted it was found that the data for agricultural vehicles was very poorly recorded. Registration data only appeared to be available for 39% of cases (normally around two- thirds) and although vehicle make was routinely recorded in those linked cases, vehicle model was only rarely completed. A literature search has also revealed no studies that contained such information in an unambiguous form. (Bende & Kuhn, 2011) did contain information on the speed the agricultural vehicle was travelling at before impact. They found that 53% of collisions involved an agricultural vehicle travelling at 20 km/h or less while only 4% involved a tractor travelling at in excess of 40 km/h. However, the study did not provide any information on the speed capability of the tractors involved, which is critical to the correct understanding of the risks. The authors of the study were contacted directly to ask if they had any additional information that could be useful. They responded that there was no direct evidence of the speed capability of the vehicles but that 20% of the agricultural tractors involved in the accident data sample, had an engine power in excess of 74 kW. Engine power can form a partial proxy for speed capability because only higher-powered vehicles will be offered with high speed capability. This could also be seen by the fact that 86% of the 4% of vehicles that were travelling at between 41 and 60 km/h had an engine power in excess of 74 kW.

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The data used by (Bende & Kuhn, 2011) related to collisions in the year 2008. Data on the stock of tractors in Germany was identified for 2012 but not earlier. This data showed that around 22% of tractors had an engine power in excess of 70kW and 4.8% had a max speed capability of 41 to 60 km/h. Given the slightly rising trend over time, it therefore appears that the collision involvement is broadly in line with the exposure in terms of the number of vehicles with the relevant capabilities. This relationship with exposure also applies across different countries. For example, the project team were provided with an analysis of road accident data in Italy4 that aimed to evaluate the statistical relevance of ABS on Agricultural tractors with a maximum speed in excess of 40 km/h. A range of collision data was analysed, examining for example, the proportion of all collisions that involved an agricultural vehicle, age of the vehicle and police reported causation factors in relation to brakes and driver error. They concluded that ABS fitment would be irrelevant to reduce road accidents in Italy. However, currently tractors capable of exceeding 40 km/h are not permitted in Italy so, by definition, none of the accidents studied would have occurred with a tractor speed exceeding 40 km/h and therefore cannot provide direct insight into whether ABS would provide a safety benefit or not. The conclusion of the work stands true only for as long as Italy does not permit high speeds.

4.3.5 Age of tractors involved in collision Analysis by (CEMA, 2015) concluded that the main problem with road accidents with tractors was older machinery. They analysed CARE data for seven EU states that had tractor age availableDraft5. They found that 56% of all road accidents with tractors resulting in injury (and 69% of fatal accidents with tractors) involved tractors that had been in use for more than 12 years. They combined this data with separate data relating vehicle age to average hours of use to show that the risk of an accident per hour of use dramatically increases when the tractor age exceeds 12 as reproduced in Figure 4.11.

Figure 4.11: Risk per operating hour of a road accident involving a tractor by age of tractor involved Source: (CEMA, 2015)

4 PowerPoint slides provided by FederUnacoma, titled ‘Accidents with AG machinery & tractors in Italy’.

5 Austria, Finland, France, Germany, Italy, Spain, UK

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It can be seen that the biggest increases in risk are for tractors aged 21+ at the time of the collision. An analysis of collisions in Great Britain has been undertaken using collision data from the years 2005 to 2015. This has been divided by the age of the tractor at the time of collision, thus a 5-year-old tractor in Figure 4.12 may have been 5 years old in 2005 or in 2015, such that it could have been manufactured at any time between 2000 and 2010.

Draft

Figure 4.12: Cumulative proportion of GB casualties, by severity, from collisions involving an agricultural vehicle by age of agricultural vehicle involved Source: Analysis of Stats19 data

The results here are in stark contrast to those identified by (CEMA, 2015). In Great Britain over the most recent 11-year period available, less than 20% of casualties involving agricultural vehicles involved one that was more than 12 years old and there was little difference for different collision severities. In fact, this data strongly suggests that young vehicles are involved in most collisions with 60% of all casualties and fatalities occurring in collisions involving agricultural vehicles aged 5 years old or less at the time of the collision. (CEMA, 2015) measured exposure to risk in terms of operating hours and equivalent data was not available for Great Britain. Thus, identical collision rates could not be calculated. The number of registered vehicles is often used as a proxy for exposure and the average age distribution of the fleet is shown as a cumulative frequency plot in Figure 4.13. It can be seen that during a very similar time frame, less than 30% of registered agricultural vehicles were less than 5 years old but these were responsible for around 60% of casualties. Although we have no national data available regarding the on-road distances driven by agricultural vehicles, anecdotal evidence suggests that it is likely to be the explanation. That is, the newest vehicles travel much larger distances on the road than older vehicles. This behaviour can be observed to be true in other forms of road transport, including both passenger and goods vehicles. This hypothesis is supported by the results of a survey of agricultural contractors in the UK (NAAC, 2017). Although only one part of the market, and the part most likely to use tractors very intensively, the results showed that the majority of road use was

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undertaken with more powerful tractors and that these would be used for up to around 1,500 hours per year and would be replaced around every 5 years.

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Figure 4.13; Cumulative frequency of number of agricultural vehicle registrations in the UK by age of vehicle Source: DfT vehicle licensing statistics

It is possible to calculate a casualty rate per 100,000 registered vehicles for each casualty severity and for each age of vehicle. In order to quickly view how this casualty rate changes with age of vehicle, this has been plotted as an indexed casualty rate. That is, one year old vehicles have been selected as the reference point and separately for each casualty severity, other ages have been referenced to 1 year old vehicles such that a value of 2 would suggest the rate for that age of vehicle is double that of a 1 year old vehicle and a value of 0.5 would show a rate half that of a 1 year old vehicle. The results are shown in Figure 4.14. It can be seen that collision rates are much lower for vehicles of less than 1 year old than they are for 1 year old vehicles. This is an artefact of the data. The number of vehicles registered is measured on the last day of the year. Vehicles less than 1 year old at that time might have been registered on the 1st day of the year but may equally have only been registered the very same day. Thus, on average, they will have been on the road for much less time than 1 year old vehicles and the expectation would be that the average would be around half a year each. Although data on fatalities is subject to large annual variations as a consequence of low numbers, it can clearly be seen that the collision rate per registered vehicle is highest for new vehicles and becomes very low for old vehicles. Based on anecdotal evidence around road use, it is highly likely that this is strongly related to declining road travel as vehicles age. It should also be noted that when comparing to the (CEMA, 2015) profile that if usage (operating hours or kilometres driven) declines with age faster than the number of collisions do, then the rate per unit of use may still increase for older vehicles.

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1.40

1.20

1.00

0.80

0.60

(1year old =1) (1year 0.40

0.20

0.00 0 5 10 15 20 25 30 Index casualtyof risk per 1,000 registered vehicles -0.20 Age of vehicle at time of collision (years)

Serious Slight Fatal

Figure 4.14: IndexDraft of casualty rate per 100,000 registered vehicles by severity and age of vehicle (1 year old vehicle = index of 1)

However, it is clear, based on GB data at least that newer vehicles will be involved in the majority of on-road collisions. In all other comparisons, the GB data has followed very similar patterns and trends to that of the EU suggesting that GB is broadly representative of the EU when it comes to agricultural vehicle collisions. However, the basic input numbers that (CEMA, 2015) is likely to have been based on have been independently checked and the difference does seem to be genuine, as shown in Table 4.4.

Table 4.4: Proportion of collisions involving 1 agricultural vehicle by age category of the agricultural vehicle, excluding unknowns. Source (European Commission, 2017)

Age category of agricultural vehicle Country <=12 years >12 years Austria 31% 69% Germany 52% 48% Spain 33% 67% Finland 64% 36% France 36% 64% Italy 40% 60% United Kingdom 88% 13% EU-7 49% 51%

The reason for the differences in this particular field is not known.

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4.3.6 Vehicle Mass The Gross Vehicle Weight (GVW) of agricultural vehicles is also understood to have increased over recent times and to be correlated in recent years with an increase in maximum speed capability. The GVW of a vehicle involved in a collision can be obtained by linking Stats19 to vehicle registration databases. This link was found to be effective in only around 75% of cases. For those cases that did successfully link, the GVW was unknown in 82% of cases. Thus, the results from the small number of remaining cases have the potential to be significantly inaccurate if there is even a small systematic bias between known and unknown cases. Where known, the distribution of fatalities by mass of tractor was as shown in Table 4.5, below.

Table 4.5: Distribution of GB casualties from collisions involving agricultural vehicle by GVW of agricultural vehicle (2005-15). Source: Analysis of enhanced Stats19 data

Gross vehicle weight Proportion of casualties (tonnes) Fatal All severities <5t 19% 13% 5 – 10t 56% 69% Draft10 – 15t 17% 15% >15t 8% 3%

It can be seen that tractors in the range of 5 to 10 tonnes are most frequently involved in all casualties and fatalities, though vehicles of other sizes (lighter and heavier) have a bigger share of fatalities than all casualties suggesting collisions involving those vehicles may be more severe. However, it is worth re-emphasising the large potential for bias as a consequence of many unknowns and the numbers involved were clearly too small for any meaningful analysis of trends over time.

4.3.7 Collision type Increasing average speed and decreasing differential speeds between vehicles has been shown to have the potential to change the type of collisions seen (see Section 4.1). ABS in other vehicle types has also been shown to affect the type of collisions seen. It has been estimated that high speed tractors will have penetrated the market to a significant degree but that ABS will remain at negligible market penetration for the years considered. A high level indication of the type of collisions sustained by agricultural vehicles can be obtained by considering the road user categories injured in those collisions. The distribution of fatality types is considered in Figure 4.15, below for the EU and in Figure 4.16, below for Great Britain. It can be seen that the distribution of fatality types from collisions involving agricultural vehicles is substantially different in the GB data to the EU data. Across the EU as a whole, tractor occupants are the most commonly killed road users in collisions involving agricultural vehicles, despite the mass ratio advantage that they would enjoy over most other road users and the relative hostility of the agricultural vehicle structures that would contact other road users. Car occupants and moped and motorcycle riders as a group are jointly next most important but still less in combination than the tractor occupants. This pattern is reversed in the GB data where agricultural vehicle occupants represent only 12% of those killed in collisions involving agricultural vehicles. When all motorcycles, regardless of engine size, are considered as one group they are most important with a combined 40% of fatalities, closely followed by passenger cars at 36%.

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Figure 4.15: Distribution of EU fatalities from collisions involving agricultural vehicles by class of road user DraftSource: Analysis of CARE database

Figure 4.16 Distribution of GB fatalities from collisions involving agricultural vehicles by class of road user Source: Analysis of Stats 19 database

The reason for this fundamental difference was unknown and so investigated in more detail. The CARE data was examined in more detail to look for differences between the 8 different Member States representing the largest contribution to the overall EU agricultural vehicle collision population6. In this case, it was found that while the GB pattern was different to the majority of Member States it was broadly similar to Germany

6 Germany, Greece, Spain, France, Italy, Poland, Portugal and the UK

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and France. Thus, there seems to be a divide between UK, Germany and France and the other 5 major contributors to EU agricultural vehicle collisions. The reason for the differences is unknown but could potentially relate to the extent to which agricultural traffic mixes with other forms of traffic. Stats19 records in one field whether the vehicle in question skidded, overturned, and/or jack-knifed. The number of casualties from accidents involving an agricultural vehicle are shown below, divided by whether or not the agricultural vehicle suffered on of these braking instabilities.

Table 4.6: The number of casualties from collisions involving an agricultural vehicle by agricultural vehicle instability type and year. Source: Analysis of Stats 19 accidents

Instability Type Year Skidded and Jack-knifed None Skidded Jack-knifed Overturned overturned & overturned 2005 918 39 16 4 5 52 2006 823 49 19 10 5 34 2007 876 49 11 6 2 28 2008 732 39 10 10 10 42 2009 Draft681 40 6 1 7 35 2010 684 47 12 19 3 30 2011 613 39 10 4 12 31 2012 728 35 8 13 14 30 2013 613 31 7 14 7 39 2014 658 34 6 8 6 24 2015 561 33 5 3 9 26 Total 7887 435 110 92 80 371 Distribution 88% 5% 1% 1% 1% 4%

Figure 4.17: Trend in the proportion of casualties (all severities) from collisions involving an agricultural vehicle that skidded and/or jack-knifed Source: Analysis of Stats 19 data

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When considering the possible influence of ABS alone on collisions above, then the main categories will be skidded, skidded and overturned, jack-knifed, and jack-knifed and overturned. It is unlikely that ABS will influence collisions where the agricultural vehicle purely overturned without skidding. ABS may influence some of those collisions where there were no instabilities, if it improved the stopping performance of the brakes. However, these have been ignored for the purposes of this analysis. Thus, it can be said that a maximum of around 8% of all collisions might be in scope of the ability of ABS to reduce braking instabilities, with additional unidentified casualties in scope of any ability to reduce stopping distance. The trends over time in these ‘in-scope’ skidding and jack- knifing collisions are unclear because there is considerable year on year fluctuation, as shown in Figure 4.17. It can be seen that there is some suggestion of a changing trend first increasing then decreasing but the correlation is extremely weak and it is not likely to differ significantly from what might occur by random chance. While ABS fitment in agricultural tractors will have remained low throughout this period, market penetration of high speed tractors will have been increasing substantially. It might, therefore, have been reasonably expected that the relative frequency of jack-knife might have increased. However, during this period some important changes were made to tractor-trailer braking practice in the UK and Ireland. As 50 km/h tractors started to penetrate these markets tractor manufacturers began to experience abnormally high levels of tractor brake failure under warranty, to the extent that at the peak the majority of warranty claims for tractor brake failure were originating from the UK and Ireland. Investigations Draft by manufacturers and independent bodies (Scarlett, 2009) revealed that the problem could usually be traced to sub-standard trailer braking system performance and, as such, manufacturers began rejecting tractor warranty claims, charging farmers for the brake repairs and publicising both the nature of the problem and potential solutions to it (Scarlett, Harding, & Wyatt, 2010). This prompted a substantial voluntary improvement in the standard of trailer brakes from around 2010/11 with a fairly pronounced move, both on the part of trailer manufacturers & purchasers, towards higher performance pneumatic braking systems for trailers. It was then found that stiff trailer suspension and poor load sensing led to problems with excessive tyre wear as a consequence of frequent wheel lock when braking whilst unladen or lightly-loaded (see Section 6.3), which has also acted to promote an increase in voluntary fitment of trailer ABS. Thus, while increased speed capability would be expected to increase the incidence of jack-knife, the improvement in trailer brakes would be expected to have decreased it. It is possible that these trends have cancelled out to result in the actual observed trend.

4.3.8 Contributory factors The GB accident data also includes an assessment of the factors that contributed to the collision. This is completed by the reporting police officer within a short time of the collision and it is not therefore an expert assessment of causation after extensive investigation. It is also only recorded in cases where the officer attended the scene. A selection of contributory factors that were considered potentially relevant to tractor speed and/or braking instability were examined for the years 2005-15. The proportion of casualties where each of the selected factors were recorded is shown in Table 4.7. The factors were selected for their relevance to ABS and high speed tractors. However, data from a small sample of collisions in Switzerland (CEMA, 2017) suggested that broadly speaking the top 5 ‘causes’ of collisions were rollover (24%, arguably this is a collision mechanism not a cause, i.e. the rollover is an event caused by driver error, excess speed, vehicle defect, etc.), behaviour of other road users (20%), operator visibility (15%), machine maintenance (13%) and vehicle driver behaviour (11%). This has been summed to say together these factors are responsible for 80% of on-road collisions, though this is highly unlikely to be the case because collision data almost

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always allows more than one contributory cause to be coded per collision such that many collisions might have had more than one of these factors involved.

Table 4.7: The frequency with which selected contributory factors were applied to the agricultural vehicle involved in the collision. Source: analysis of Stats 19 data

Contributory factor Proportion of all casualties Proportion of fatalities Loss of control 3.4% 6.0% Travelling too slow for conditions 2.9% 4.8% Defective brakes 0.9% 2.4% Slippery Road 3.1% 2.0% Exceeding speed limit or travelling 2.7% 2.0% too fast for conditions Sudden braking 1.6% 1.2%

The incidence of rollover can be seen to be very high compared with the GB data (rollover involved in 10% of casualties). In-depth data from GB (Knight I. , 2001), though historic, also shows both some difference and some commonality. In a detailed study of 41 fatal collisions involving agricultural vehicles it was found that 39% of agricultural vehicleDraft drivers at least contributed to the cause of the collision, while 81% of other vehicle drivers contributed. Thirty nine percent of the agricultural vehicles involved were suffering some form of mechanical defect but in most of these the defect did not contribute to the cause of the collision. Approximately 12% had defects that were considered contributory and these were most often lighting defects or defects in the coupling between tractor and trailer.

4.4 Accidents involving SbS and ATVs All-terrain vehicles (ATVs) and Side-by-Side vehicles (SbS) are not recorded as a separate category in any of the collision data available. In Great Britain, for a proportion of collisions, it is possible to link the collision data to registration data such that the make and model of vehicle can be identified. An analysis was undertaken for collisions in the years 2011 to 2015 that sought to identify known ATVs or SBS vehicles by their make and model. In total, 135 vehicles were identified and they were involved in collisions of the following severity.

Table 4.8: Number of collision-involved vehicles by year and collision severity

Year Fatal Serious Slight Total 2011 4 4 2012 2 9 11 2013 3 10 26 39 2014 21 26 47 2015 2 11 21 34 Total 5 44 86 135

These vehicles were classified as many different Stats19 vehicle types, mainly ‘other’ but also ‘car’ and ‘powered two wheeler’ (PTW). It can be seen that the overlap with the analysis of agricultural vehicles in the preceding section will be very small.

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Table 4.9: Number of collision-involved vehicles by Stats19 vehicle type and collision severity

Vehicle type Fatal Serious Slight Total PTW 2 18 20 Car 2 10 12 Agricultural 1 2 3 Other 5 39 55 99 unknown 1 1 Total 5 44 86 135

The type of road user injured in collision with these vehicles is almost always the driver or rider of the vehicle (84%) or a passenger on the vehicle (15%). Less than 1% (1 case) involved a pedestrian. Overall, there were 141 casualties identified from collisions involving these vehicles, compared with a total for agricultural vehicles (mainly tractors and trailers) of 3,667 in the same time period. Thus, the scale of the problem involving SBS and ATVs is approximately one 26th of that of other agricultural vehicles. Draft

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5 Overview of anti-lock braking systems (ABS)

5.1 Current use of ABS on agricultural vehicles The primary purpose of a vehicle anti-lock braking system (ABS) is to minimise / prevent loss of tyre - ground surface adhesion during braking, thereby avoiding wheel locking / skidding and permitting steerability of the vehicle to be maintained (see Figure 5.1 and Section 5.2). However, vehicle stopping distances are also reduced, particularly on low-adhesion surfaces, and vehicle stability improved, particularly in the case of tractor-trailer combinations (see Section 5.2). Indeed, notes to the German National Braking Regulations (as cited by (Moore, 2015)) apparently state that: “the main benefit of ABS is not just a potentially shorter stopping distance, but rather the fact that, in emergency stops, the vehicle’s steering and ride stability is maintained such that obstacles can be negotiated and any gaps between them can be utilised to prevent collisions.” Draft

Figure 5.1: Maintaining tractor steerability during braking through use of ABS (Copyright CNH Industrial)

During ABS operation, sensors monitor the rotational speed of the vehicle’s wheels and (if during braking) the speed of one or more wheels reduces significantly relative to the others, vehicle braking effort is automatically modulated by rapid release and then subsequent re-application of the brakes; this is normally achieved by reducing and then increasing braking system actuation pressure. ABS is far from a new concept: having originally been developed to improve aircraft stability whilst braking during landing, the technology was transferred to trucks and buses in the 1970s, becoming a mandatory fitment by the late-1980s. The technology has then since been transferred and today is in widespread use upon both passenger cars and motor cycles. ABS first became available on more specialised, transport-orientated tractors in the early-2000s: they have since been offered by certain manufacturers as optional equipment on a very limited number of ‘conventional’ Category T1 tractor models since 2010 (see Section 5.1.1). As discussed in Section 2.3, the Relevant Agricultural Vehicle (RAV) grouping considered by this study comprises the following vehicle categories / types in the

40 < Vmax ≤ 60 km/h speed range:

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 T1b: ‘Conventional’ agricultural tractors.

 T2b: Narrow-track agricultural tractors.

 T4.3b: Low-clearance, low centre-of-gravity (CoG) transporter-type tractors.

 ATV: All-Terrain Vehicles type approved as Category T1.

 SbS: Side-by-Side utility-type vehicles type approved as Category T1 or T3.

 R3b: Agricultural trailers of 3500 < MPMaxles ≤ 21000 kg.

 R4b: Agricultural trailers of MPMaxles > 21000 kg.

 S2b: Interchangeable towed equipment of MPMaxles > 3500 kg.

The generic ABS systems which are (currently) technically-available for use upon agricultural vehicles may be categorised according to the following characteristics:

 The medium used within the ABS control / modulating valve(s), e.g. air, automotive-type brake fluid or mineral hydraulic oil.

 The medium used to actuate the vehicle’s (foundation) brakes, again either air, automotive-typeDraft brake fluid or mineral hydraulic oil. Automotive (on-road vehicle) ABS systems frequently utilise the same medium for both brake control / modulation and subsequent brake application, but the specific demands of off-road / agricultural vehicles and their braking systems often requires a more flexible approach. This is primarily dictated by the brake application method / medium used on the vehicle, but other factors, including the construction of the vehicle, the available space for ABS component installation and the availability of a compressed air braking system (either for the target vehicle or trailers / equipment towed by it), also can influence the practicality and cost of ABS installation. The generic ABS systems which, in the view of this investigation, are potentially suitable for use upon agricultural vehicles are summarised by Table 5.1. Information gathering by the investigation, by means of manufacturer and stakeholder surveys, face-to-face meetings and review of relevant literature (see Section 1.2) returned the following insight into the current availability of ABS on agricultural tractors and vehicles type-approved as agricultural tractors. Of the 10 manufacturers of Category T1 or T1 and T2 tractors who responded to the survey:  One manufacturer offers ABS as standard (although the number of models is currently unknown) on all T1 models irrespective of whether the maximum design speed is Vmax < 40 km/h, 40 < Vmax ≤ 60 km/h or Vmax > 60 km/h.  Two manufacturers offer ABS as an optional extra (on 6 model ranges and 1 model range respectively). It is noted that neither manufacturer produces

Vmax > 60 km/h vehicles.  Seven manufacturers do not offer ABS as standard or as an option on any of their models. It is noted that none of these manufacturers produces Vmax > 60 km/h tractors.

 Seven manufacturers produce T2a Narrow-Track tractors (Vmax ≤ 40 km/h), but none currently offer T2b (Vmax > 40 km/h) models. Consequently, at least at present, ABS provision does not appear to be an issue for such (narrow-track) tractors.

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No manufacturers of Category T4.3 (Low-clearance, low-centre of gravity, transporter- type tractors (see Section 2.3.3)) were found to currently offer ABS on their vehicles, despite the availability of T4.3b (Vmax ≤ 50 km/h) versions. However, given that such vehicles’ service braking systems are largely of conventional, automotive-type design, it is understood that they may accept off-the-shelf hydraulically-actuated ABS systems from the light-duty truck sector with minimum modification, assuming the functionality of such systems is deemed adequate for the application. It is understood that no manufacturers of Side-by-Side (SbS) vehicle or All-Terrain Vehicles (ATV) currently offer vehicles with ABS. However, the investigation has been informed that this situation is due to change in the near future, albeit details of the ABS system (believed to be for an ATV) have not yet been provided.

This change in system provision has apparently resulted from the fact that the Vmax capability of both vehicle types can be up to 65 – 80 km/h, but it is usually limited (by electronic engine management system) to Vmax ≤ 40 or ≤ 60 km/h when models are type-approved as agricultural tractors. It is understood that a manufacturer wishes to type-approve a Vmax > 60 km/h ATV as an agricultural tractor and so, in order to comply with the current requirements of (EU) 2015/68 (European Union, 2015), intends to install ABS on the vehicle. It is assumed this will be an automotive-type system, but precise details are not known.

Table 5.1: GenericDraft ABS systems potentially suitable for use on agricultural vehicles ABS Type Brake System Availability for (System Modulating Actuation Off-Road / Agricultural Comments / Control Medium) Medium Vehicles Truck ABS-derived system. Requires (1) Pneumatic Pneumatic Yes – Mature compressor & air reservoir(s) on vehicle Adaptation of (1). Only suitable for Hydraulic – vehicles with limited brake (2) Pneumatic Yes - Mature Brake Fluid application fluid displacements (e.g. external disc brakes) Adaptation of (1). Suitable for Hydraulic – (3) Pneumatic Yes - Mature hydraulically-applied (internal) Mineral Oil tractor disc brakes (very common) Yes/No – Some Mature Derived from Automotive (Light systems / some Proof- Truck or Car) systems. Low (4) Hydraulic – Hydraulic – of-Concept – Each only installation space requirements. Only Brake Fluid Brake Fluid suited for certain suitable for vehicles with limited (lower mass) vehicle brake application fluid displacements applications (e.g. external disc brakes) Particularly suited to hydraulic oil- (5) Hydraulic – Hydraulic – Yes/No – Systems applied braking systems (e.g. many Mineral Oil Mineral Oil under Development tractors). Lower installation space requirements

Note: Where systems are stated as ‘Under Development’ or ‘Proof of Concept’, we have been informed that that the estimated time to market readiness / series production will be within the timescale of the currently- proposed legislative deadline for mandatory ABS introduction on 40 < Vmax ≤ 60 km/h agricultural tractors.

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5.1.1 Current Category T1 tractor ABS systems As previously discussed, current ABS systems used on agricultural tractors may be categorised according to the medium used within the ABS control / modulating valves (e.g. air, automotive-type brake fluid or mineral hydraulic oil) and the medium used to actuate the vehicle’s (foundation) brakes (again either air, automotive-type brake fluid or mineral hydraulic oil). Of the three T1 tractor manufacturers who currently offer ABS on some / all of their products (i.e. Fendt, CNH Industrial and JCB (see Table 5.2)), the particular systems chosen and their methods of implementation highlight the diversity of tractor design / construction and the requirement to develop somewhat bespoke solutions to achieve the same objective.

Table 5.2: Agricultural vehicles which currently offer ABS systems

Vehicle Brake Vehicle ABS Modulating / Vehicle Make / Model Actuation Comments Type Control Medium Medium Fendt 900 Vario ABS offered as option Pneumatic Pneumatic series (~€5k) New Holland T7 LWB ABS offered as option with & T7 HD series plus Hydraulic Basic (~€4k) or T1b Pneumatic associatedDraft Case-IH & (mineral oil) Enhanced (~€5k) Steyr models functionality JCB Fastrac (all Hydraulic ABS standard fitment Pneumatic models) (brake fluid) across entire vehicle range T2b vehicles are currently T2b - - - not produced T4.3b - - - ABS not offered ABS currently not offered but is expected in the near ATV - - - future from one manufacturer – cost unknown ABS not offered but may be SbS - - - available in the near future ABS offered either as a Various – widely basic system (~€500 – available as option on Pneumatic Pneumatic 1000) or as part of an EBS larger trailers R3b / (Electronic Braking System) (MPM ≥ 12000 kg) R4b axles (~€3.5 – 5k)

- Hydraulic - ABS not available

Typically only offered on large / heavy vehicles which (due to mass ratio) Various Pneumatic Pneumatic are classified as S2b Category R. Same systems as used on Category R.

- Hydraulic - ABS not available

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The optional ABS systems offered on the 180 – 240 hp (134 – 180 kW) New Holland T7 LWB series and the 270 – 300 hp (200 – 224 kW) T7 Heavy-Duty series tractors (Figure 5.2) provide a good illustration of the typical problems which are likely to challenge the installation of ABS on T1 tractors (Figure 5.3). In common with the majority of conventional T1 tractors (see Table 6.1), the front and rear axle service brakes of these tractors are internally-housed, oil-immersed units, actuated hydraulically by a servo- assisted system utilising mineral hydraulic oil. However, at the time of system development, no ABS system utilising this medium was commercially-available.

Figure 5.2: New Holland T7 LWB tractor (left) and T7 Heavy-Duty tractor (right) Draft (Copyright CNH Industrial)

Figure 5.3: Air-over-hydraulic ABS installation on New Holland T7 LWB series (180- 240 hp) tractors and comparable Case-IH & Steyr models (Copyright CNH Industrial)

CNH Industrial therefore choose to employ a readily-available pneumatically-operated ABS system, to convert the operator’s foot brake control to a pneumatic system, and then to convert the pneumatic output of the ABS module back to hydraulic pressure (via

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three dedicated Air-over-Hydraulic converter units) to enable actuation of the front and rear axle brakes. Three converter / actuators are required because, in common with most tractor braking systems and, indeed all current tractor ABS systems, whilst the front axle has individual brake units for each wheel, they are controlled as a pair. However, the rear axle wheels each have individual brakes which are controlled separately. This permits the ABS system to provide enhanced vehicle control when braking with the left and right wheels on surfaces of different adhesion (split-μ). It also permits independent rear wheel brake application to permit tighter turning at low speeds in-field. Sensors are installed within the front and rear axle housings to monitor the rotational speed of each wheel (Figure 5.3). Consequently the ABS system senses wheel speed at each wheel, but only modulates braking effort across (effectively) three wheels (front pair and each rear wheel). Such configurations are known as 4-sense / 3-modulate (4S / 3M) systems. However, ABS installation was found to be far from a trivial task: compared with the standard (non-ABS) model, the vehicle required a larger air (braking) reservoir capacity, a water cooled air compressor, a dedicated brake circuit and air brake circuit, an Electronic Control Unit to control the service brakes and provide ABS functionality, an ABS distribution valve, three pneumatic-over-hydraulic actuators and speed sensors for each wheel. Draft

Figure 5.4: Schematic layout of Fendt 900 Vario braking system (standard model) (Copyright AGCO GmbH)

The challenges to ABS installation on the 275 – 395 hp Fendt 900 Vario vehicle models (Figure 3.7) were marginally fewer in number because, whilst they also utilise internally- housed, oil-immersed brakes on the front and rear axles, unlike the CNH / New Holland tractors, the service brakes of the Fendt tractor are operated by pneumatic actuators. Theoretically this permitted a pneumatic based ABS system to directly interface with the existing vehicle service braking system (Figure 5.4). However, other challenges remained in terms of wheel speed sensor installation and configuration of the ABS system to interact and operate effectively with the vehicle’s four-wheel drive (4wd) driveline and continuously-variable transmission (CVT). Unlike the New Holland installation, Fendt chose to install wheel speed sensors externally at the axle ends but, in common with the New Holland system, a 4-sense / 3-modulate 4S / 3M ABS configuration is employed.

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JCB were one of the first manufacturers to provide ABS on an agricultural tractor, introducing a system on their Fastrac vehicles in 2001. There are currently three model ranges of Fastrac vehicle (Figure 3.7), covering the 160 – 350 hp (120 – 260 kW) power range. They are specifically-designed to deliver superior performance in transport applications, compared with conventional tractors. This is reflected in the provision of both front and rear axle suspension and Vmax = 70 km/h capability. However, the Fastrac is type-approved as a Category T1b vehicle. The ABS installation on the Fastrac was probably the most convenient of the three examples presented here (i.e. New Holland, Fendt and JCB) because the vehicle utilises a pneumatically-controlled and hydraulically-actuated (air-over-oil) service braking system. Automotive-type dry-disc and caliper-type brake units are mounted externally at the axle ends (Figure 5.5) and are actuated hydraulically using automotive-type brake fluid. Whilst this type of foundation brake is found on some tractor 4wd front axle installations, it is a relatively uncommon solution for both the front and rear axles of a vehicle. Draft

Figure 5.5: Vehicle chassis configurations of JCB Fastrac 3000 series (left) and 8000 series (right) (Copyright JCB)

The benefit in terms of ABS installation is that, as subsequently found by New Holland, it is possible to utilise pneumatic ABS control hardware derived from on-road (truck) applications. The pneumatic-to-hydraulic converters required to enable brake actuation were already fitted to the Fastrac vehicle. However, this is not to underestimate the considerable effort required to develop appropriate ABS operating / control strategies for effective system operation in on-road and off-road conditions, in different loading conditions (e.g. with / without front and/or rear mounted implements) and when towing trailers with / without mass transfer characteristics (e.g. balanced / unbalanced).

5.1.2 Current Category R3 / R4 trailer ABS systems As far as this investigation has been able to determine, at present there are no commercially-available ABS systems for agricultural trailers or interchangeable towed equipment equipped with either inertia or hydraulically-actuated service braking systems. The absence of inertia-based ABS systems is not a restriction because inertia-operated brakes are not permitted on R3b, R4b or S2b vehicles (Table 2.1). The current absence of ABS systems for high-pressure hydraulically-actuated ‘trailer’ braking systems is an undoubted disadvantage. However, at this present time, hydraulic trailer braking systems are very rarely (if ever) used on agricultural trailers of Vmax > 40 km/h. The current national regulations of EU Member States which do permit the use of agricultural trailers at > 40 km/h (Section 3.4) require braking system functionality which cannot be met by simple single-line hydraulic braking systems. This has resulted in the widespread use of dual-line pneumatic systems for agricultural trailers

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and related towed equipment of Vmax > 40 km/h. Given the common use of this braking hardware on trucks and buses, the cost-effectiveness of such systems (~€600 / vehicle) is now so great that it is unlikely a hydraulic braking system with equivalent functionality could be economically-competitive. In combination these factors make the future commercial development of ABS systems for hydraulically-braked Vmax > 40 km/h agricultural trailers / towed equipment very unlikely. A dual-line pneumatic braking system is therefore currently a prerequisite for ABS installation upon agricultural trailers or interchangeable towed equipment but, generally, such systems are only found on trailers of larger mass / carrying capacity. Two contrasting (but nonetheless related) approaches appear to be employed for the provision of ABS functionality in such instances:

 Numerous UK manufacturers of larger (payload ≥ 14,000 kg, MPMaxles> 16000 kg) agricultural trailers offer ABS as optional equipment on their vehicles, if they are fitted with conventional, dual-line pneumatic braking systems (Figure 5.6). The ABS systems employed are direct derivatives of truck-trailer systems and, due to automotive volumes, are seemingly very cost-effective. UK trailer manufacturers currently offer such systems for ~€500 – 1000 retail and have done so for many years. The systems are also available for retro-fit installation to existing pneumatically-braked trailers / towed equipment.  Certain German and Austrian trailer and/or towed equipment manufacturers provide ABS functionality by installing truck-type electro-pneumatic EBS (Electronic Braking System) technology (Figure 5.7). This high-end, intelligentDraft system can provide many features in addition to ABS (e.g. active vehicle stability control), but it is more costly than a basic pneumatic trailer ABS (€3500 – 5000 cited). Additionally, in the view of certain survey respondents, the presence of EBS (a relatively new technology in agricultural applications) may make a second-hand vehicle less attractive to secondary or tertiary users.

6 5 5

5 5 6

Figure 5.6: Agricultural trailer dual-line pneumatic braking system incorporating ABS (N.B. Single-line hydraulic braking system installed in parallel) (1) pneumatic control line, (2) pneumatic Supply line, (3) hydraulic supply / control line, (4) trailer ABS power & warning light lead, (5) pneumatic brake actuators, (6) wheel speed sensors, (9) Relay/Emergency/Load-Sensing Valve, (10) ABS ECU & modulator valves, (11) hydraulic brake actuators (Copyright J H Milnes Ltd)

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Figure 5.7: Schematic layout of a (truck-type) centre-axle trailer with EBS and ABS (N.B.: Certain features (e.g. pneumatic axle suspension) may not be present on Draftagricultural vehicles) (Copyright Knorr-Bremse GmbH)

5.2 The effectiveness of ABS Braking systems at the most basic level are required to stop a vehicle quickly and in a safe and stable manner. Braking so hard that the wheels stop turning can have effects on both of these properties. The effect of locked wheels will vary with a range of other parameters including vehicle speed, surface friction properties, tyre slip characteristics, and driver steering activity. Thus, systems such as ABS that act to prevent wheel lock will affect only a certain subset of collisions.

5.2.1 Stability and steerability during braking One of the basic properties of road vehicles is that their tyres can only generate sideways forces when they are rolling. Once fully locked tyre side force drops to zero. The effect of this varies depending on which wheels lock, as illustrated in Figure 5.8, where locked wheels are shaded red. The graphic was produced in relation to HGVs but the principles are directly applicable to agricultural vehicles. If the wheels on the front axle lock and can no longer generate side force, then there is a loss of steering control. That is, the vehicle will continue in a straight line tangential to the path it was following at the moment the wheels locked, regardless of driver input at the steering wheel. This is the case regardless of whether or not the vehicle is towing a trailer. The rigid truck shown is directly equivalent in this case to a solo tractor, ATV or a side by side vehicle. If the wheels on the rear axle lock while the front wheels remain rolling then the vehicle will tend to spin. If the vehicle is towing a trailer and the rear wheels of the towing vehicle lock then the towing vehicle begins to spin while the trailer remains stable. This is called jack-knife. If the rear wheels of the trailer lock while the tractor remains stable then the trailer begins to rotate around the coupling and this is called trailer swing.

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Figure 5.8: Illustration of the effect of locked wheels on braking stability

It can be seen that only two of the four possible instability mechanisms identified, are applicable to rigid vehicles. The remaining two can occur only with tractor trailer combinations or articulated vehicles. The effects of these braking instabilities are highly dependent on speed. Significant departures fromDraft the intended path and/or heading of the vehicle take time to develop. At low speeds, provided the vehicle has brakes of basic good efficiency, the vehicle will stop in a very short distance and time. This distance or time is usually insufficient for significant instability to develop before the vehicle comes to rest. The exception is in very low friction conditions, for example road surfaces contaminated with wet mud or diesel or covered in snow or ice. (Dodd, Bartlett, & Knight, 2006) undertook extensive braking tests with agricultural tractors towing trailers. A measure of tractor stability is shown in Figure 5.9 during braking tests from 40 km/h with balances of braking across the vehicle combination. No ABS was active on either tractor or trailer during any of these tests.

Figure 5.9: Tractor stability during straight line braking from 40 km/h with different tractor trailer brake balances and no ABS Source: (Dodd, Bartlett, & Knight, 2006)

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It can be seen that only in the situations representing inadequate or defective trailer brakes was there any significant instability in the tractor. Measures to control the braking compatibility of combinations were included in the resultant revisions to the agricultural vehicle braking regulations. These measures would be expected to substantially reduce the chances of such brake imbalances in service, such that jack-knife instabilities in straight line braking should only occur at less than 40 km/h where either an old trailer pre-dating new standards is towed, trailer brakes are defective (e.g. poor maintenance) and/or where the tyre road friction is substantially reduced by ice, snow and/or contamination by mud or diesel. Additional straight line braking was undertaken at higher speed using a JCB Fastrac equipped with ABS to tow the same trailer, with and without the ABS active. The results are shown in Figure 5.10. This data confirms that 40 km/h is the speed at which instability commences for agricultural vehicles towing trailers with good brake balance across the combination, on a good clean asphalt surface wetted with water. It can be seen that ABS was sufficient to completely control this instability, even though it was only available on the tractor and not the trailer. At 60 km/h, the result without ABS was actually more severe than indicated by the graph above, the point plotted actually reflecting the moment the driver chose to abort the test due to concern over the possibility of collision between tractor and trailer and/or rollover. The brakes had to be released less than 2.5 seconds after first application. This is indicated by FigureDraft 5.11.

Figure 5.10: Tractor stability during straight line braking from higher speeds with balanced braking across the combination on a good condition asphalt surface in wet conditions Source: (Dodd, Bartlett, & Knight, 2006)

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Figure 5.11: Instability reached at the point a 60 km/h wet test without ABS was Draftaborted for safety reasons Source: (Dodd, Bartlett, & Knight, 2006)

It should be noted that these results were obtained with a balanced trailer that imposed no vertical load on the tractor. In tests with an unbalanced trailer, it was found that during straight line braking the trailer imposed sufficient additional vertical load on the tractor that even at full pedal application the rear wheels of the tractor did not lock. In this situation, ABS was not necessary to prevent instability. However, failing to reach the point of wheel lock means that the stopping distance will not be as short as it could be in this situation and manufacturers would not be prevented by regulation from increasing the power of the brakes such that they could reach the point of wheel lock even when towing an unbalanced trailer. The earlier research also compared a JCB Fastrac and a traditional tractor design from Fendt, both without ABS (Figure 5.12). The behaviour was found to be very similar and so the conclusions appeared equally applicable to both traditional and new designs.

Figure 5.12: Straight line braking, wet conditions, balanced trailer, comparison between JCB and Fendt without ABS Source: (Dodd, Bartlett, & Knight, 2006)

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(Dodd, Bartlett, & Knight, 2006) also undertook braking in a turn tests. In this case, there was a difference in performance both with and without ABS function and between the different tractors and trailers tested. The JCB Fastrac without ABS had brakes sufficiently powerful to lock both front wheels. In this case, the yaw rate (shown in Figure 5.13) drops very quickly to zero, indicating that the vehicle quickly stops negotiating the turn and commences travelling in a straight line. In an on-road situation, this is equivalent to a tractor coming around a bend, seeing a hazard ahead, applying emergency braking and then travelling in a straight line such that the vehicle either crosses into the oncoming traffic lane and/or leaves the road. The behaviour of the Fendt tractor is different from the JCB when braking in a turn. Initially, the yaw rate increases significantly before dropping steadily to zero. The Fendt tractor locked only the wheels on the inside of the curve (which would be lightly loaded because of the load transfer to the outer wheels while cornering). Thus, significant cornering forces remain. The increase in yaw rate indicates a momentary tightening of the line through the corner. That is, if the driver does not adjust the steering, then the vehicle will follow a tighter bend. If severe enough, this could cause a vehicle to leave the road to the inside of the bend. In some cases, with passenger cars, this type of behaviour is severe enough to cause a full vehicle spin. However, in this case, the tightening of the line was relatively small and should be easily compensated by the driver. It can be seen from Figure 5.13 that activating ABS on the JCB prevents the front wheel lock such that the vehicle continues to follow the bend with the yaw rate dropping steadily as theDraft vehicle comes to rest. It does this without the tightening of the line seen in the Fendt. ABS has therefore done an excellent job of stabilising the tractor.

Figure 5.13: Yaw rate time history during braking in a turn with an unbalanced trailer Source: (Dodd, Bartlett, & Knight, 2006)

However, tests were repeated with the balanced trailer (not equipped with ABS). In these tests severe instability was identified (Figure 5.14). It can be seen that in the absence of ABS, the tractor suffered a sharp increase and then large reversal of yaw rate in response to the brake application. The comparator run with ABS enable would suggest stabilisation but yaw rate was measured on the tractor only. Thus, the tractor was indeed stabilised. However, trailer swing still occurred as shown in Figure 5.15.

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Figure 5.14: TractorDraft yaw rate, brake in a turn in wet conditions JCB Fastrac with/without ABS Source: (Dodd, Bartlett, & Knight, 2006)

Figure 5.15: Illustration of trailer swing during 50 km/h brake in a turn, JCB Fastrac with ABS active Source: (Dodd, Bartlett, & Knight, 2006)

This behaviour was not confined only to the JCB. The Fendt traditional tractor showed similar behaviour as illustrated in Figure 5.16. This culminated in a full rollover of the trailer.

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Figure 5.16: Jack-knife, trailer swing and wheel lift during brake in a turn in a Fendt with balanced trailer Source: (Dodd, Bartlett, & Knight, 2006)

This track testing has proven that ABS is effective at enabling steerability under combined braking and turning and this will apply to both solo tractors and tractor trailer combinations. Although not explicitly tested, the results suggest that stability will also be maintained for a solo tractor while braking and turning. There is clear evidence that above 40 km/h jack-knife can occur in straight line braking when tractors are towing trailers. With the vehicles tested here this was much more evident with balanced than unbalanced trailersDraft but vehicles with greater brake power would behave differently. ABS stabilises combinations well in straight line braking, even when fitted only to the tractor and not the trailer. While ABS can improve tractor stability when braking in a turn, there is clear evidence that trailer swing can still occur when the trailer is not equipped with ABS. Thus, ABS is required on the full combination to fully stabilise the combination. All of these conclusions were reached on a test surface of high quality, well textured asphalt in normal wet conditions. Stability and steerability problems would be reduced in dry conditions such that the effect of ABS would be expected to be less. However, in lower friction conditions (e.g. worn asphalt wet, contamination with mud/oil etc. and/or ice or snow) then stability problems and the effect of ABS would be expected to be much greater.

5.2.2 Stopping distance Vehicles that are not equipped by ABS are generally required by braking regulations to fulfil criteria relating to ‘adhesion utilisation’. Essentially these requirements are intended to ensure that the front axle locks before the rear axle. This helps to minimise the severity of instability arising from locked wheels. The logic of this is that if the front wheels lock first, the vehicle will be travelling in a straight line at the moment the rear wheels lock. Thus, the chances of the vehicle spinning are reduced. In older passenger cars, this was often achieved by means of a simple pressure limiting valve on the rear brake circuit. This would mean that in high friction conditions, the rear wheel could end up being under-braked, increasing the stopping distance. When a vehicle is fitted with ABS, it does not have to comply with this requirement and so, in some cases, ABS can appear to substantially improve stopping distance. This is an indirect effect of the improved stability making it technically easier to design to the limit for stopping distance, rather than a direct effect of the mechanism itself. The requirement for passenger cars applies to all decelerations between 0.15 and 0.8g. For agricultural tractors, the restriction is only applied at decelerations between 0.15 and 0.3g. It is not known how the different implementation of this requirement for agricultural vehicles will affect any similar indirect improvement of stopping distance.

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The direct effect of ABS on stopping distance is in relation to the tyre road friction characteristics, in particular the relationship between tyre slip and friction. An example of this relationship is shown in Figure 5.17.

Figure 5.17: Example of tyre longitudinal slip vs friction relationship Draft

In order for forces to develop between the tyre and the road then there has to be some slip between the two. The relationship after that point varies considerably depending on the properties of both tyre and road surface and any contaminant (e.g. water) between the two. Typically the peak friction will be developed at a relatively low level of slip. Most drivers do not have sufficient skill and refinement on the brake pedal to be able to maintain wheel slip within tight margins. Thus, there is an opportunity for ABS to improve on driver performance if it can keep the wheel slip within a tight corridor (e.g. the ‘sweet spot’ identified in Figure 5.17, which is close to the peak for typical dry and wet asphalt). Typically, vehicles where the components have low inertia and the medium through which the brakes are applied is incompressible (i.e. passenger cars) can achieve very rapid and precise modulation of the brakes. This means that they can keep utilising very close to peak friction in many common conditions and reduce stopping distance compared to locked wheel braking and even skilled driver modulated braking. However, even on very good systems, surfaces with unusual characteristics can result in increased stopping distances if their slip characteristics are significantly different to those assumed in the programming of the ABS. Heavy vehicles tend to have large heavy wheels and large heavy brake components. Many of them also actuate the brakes using air, a highly compressible fluid. This introduces considerable additional inertia and hysteresis into the system and makes rapid precise modulation of brake pressure more difficult. In addition to this, tyres are designed differently and their slip characteristics might be different. This can lead to a braking characteristic more like that illustrated by Figure 5.18. This shows that although the ABS does prevent all but momentary wheel lock (which is permitted under ABS regulations), it allows wide variation in the slip experienced by the wheel (sometimes known as deep cycling of the pressure or wheel speed). This can mean that the average deceleration is considerably lower than implied by the peak available friction. Thus, increases in stopping distance relative to locked wheel braking are more likely. It should be noted that this characteristic is based on the performance of old technology from Heavy Goods Vehicles (HGVs). Technology has been improving consistently for many years and it is quite possible that it has evolved to the point that more refined slip control can improve stopping distances on a wider range of surfaces.

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Draft

Figure 5.18: Illustration of potential tyre slip characteristics and ABS actuation on heavy vehicles with high component inertia and hysteresis.

This variation of ABS stopping performance on different surfaces can be graphically illustrated in certain ‘off-road’ conditions. It has long been established in studies of passenger car ABS that greater deceleration can be achieved by a locked wheel than by an ABS controlled wheel. This is because a locked tyre will dig into the gravel and create a wedge of material ahead of the tyre, known as the wedge effect. This is demonstrated in passenger car tests undertaken by (Forkenbrock, Flick, & Garrot, 1999). Results from tests of a variety of cars on a deep gravel surface showed that on average the stopping distance of 9 cars was between 24% and 30% longer with ABS activated compared with locked wheel braking. However, when 8 vehicles were tested on grass, the stopping distance was on average 4% shorter when ABS was active. One vehicle was tested on very wet grass with standing water patches and it was found that in these conditions, the stopping distance under locked wheel braking was 30% longer than under ABS braking. This is consistent with views expressed by some agricultural vehicle manufacturers during the stakeholder consultation but others simply state that off-road performance is worse. The test results and theory would suggest the type of off road surface will have a significant effect as to whether ABS offers benefits or disadvantages. The extent to which those different surfaces are prevalent at each manufacturers test facilities may have some bearing on their views and the prevalence of different surfaces on real farms across different times of year could reasonably be expected to be a strong determinant of whether the net effect of ‘off-road’ ABS would be beneficial or not. As stated previously, braking technology has advanced significantly in recent years. Some braking systems manufacturers have proposed technical solutions to off-road performance as illustrated in Figure 5.19.

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Figure 5.19: Example of possible modifications to ABS control to improve off-road performance (Copyright Knorr-Bremse)

This proposal appears to be predicated on the basis that the vehicle will not be used at high speed in off-road conditions where the ‘wedge effect’ is likely to be significant (e.g. gravel or deep mud). At high speed it modulates the pressure to a shallow depth, meaning it willDraft control slip in a tight corridor well suited to optimising stability and stopping distance on asphalt surfaces. At lower speeds 15-40 km/h, the pressure is modulated in deep cycles that allow the vehicle to lock momentarily. This allows some of the advantage of the ‘wedge effect’ to be taken to improve off-road stopping distance at the expense of on road stopping distance but while maintaining stability in both cases. Below 15 km/h, the system is deactivated entirely. Thus, at low speed the system is optimised for off-road performance. At high speed it is optimised for on-road performance. No information has been found actually quantifying the performance of this type of system on different surfaces. The agricultural vehicle braking regulation requires that ABS can be switched off and would permit, but not require, this type of dual mode control.

5.2.3 Real world effectiveness of ABS The evidence in the preceding section shows that in physical tests, ABS is highly effective at stabilising agricultural vehicles under emergency braking. However, its effectiveness in terms of preventing collisions in real world service will depend on how often such circumstances occur on the public road, the interaction with the driver, and if there are any unforeseen consequences of fitting ABS. That is, track tests might show that ABS is highly effective at stabilising brake in a turn manoeuvres but if, in real service, tractor drivers very rarely brake in a turn then the number of instances where performance is improved will be small. Similarly, track tests can show that an ABS maintains steerability under braking but if drivers do not make rapid and appropriate steering inputs in such emergency situations the benefit will be small. If in addition, there is an unintended consequence that drivers do not like the feel of ABS modulation and release the brakes, the benefits seen on the track would be further undermined. Thus, a system that is highly effective on the test track may not be so effective in service. At a high level, there are two different ways of quantifying the likely effect of a measure:  Predictive studies: Study accidents that have occurred where the safety feature was not present and apply engineering analysis to assess what effect fitting the feature would be expected to have.

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 Retrospective studies: Comparing the accident involvement of vehicles equipped with the feature with the involvement of those that are not equipped. There are significant advantages and disadvantages to both approaches (see for example (Knight & Broughton, 2010) for a detailed consideration). Predictive studies can focus on precise system characteristics and be very specific but rely heavily on theory and cannot fully account for any behavioural adaptation or unintended consequences. Retrospective studies in theory directly measure the real change including any effect of behavioural adaptation or unintended consequences so in theory are more robust. However, it is harder to precisely isolate the variable you are trying to measure (e.g. the effect of ABS in this case) from other changes affecting crash risk that will have occurred in the same time period. As such, they can suffer from a range of confounding factors. While this can be mitigated with high quality accident and exposure data and sophisticated analytics, it is not always possible to overcome the data limitations. Results must be interpreted very carefully as a consequence. There are relatively few studies of the effect of ABS on agricultural vehicles and there are no retrospective studies. (Bende & Kuhn, 2011) studied data from insurance claims in Germany and predicted that 1% of killed or seriously injured casualties from accidents involving agricultural vehicle could be prevented by ABS and 4% of all accidents. However, correspondence with the authors reveal that this was based only on a simple assumption that all rear end collisions where the tractor driver braked would have been relevant to ABS and does not consider the level of effectiveness or the relevance of other collision types such as those involving jack-knife. In a position Draft paper on the subject of ABS (CEMA, 2013), the association of European Agricultural machinery manufacturers cited the study by (Bende & Kuhn, 2011) as evidence of their estimate that agricultural vehicle ABS would prevent 1% of fatalities and 4% of all collision involving an agricultural vehicle. In their conclusions, they stated: “No statistically significant reduction of accidents can be expected from the introduction of ABS on tractors. On the contrary, based on the experience from road vehicles, there is a significant risk that the introduction of ABS in tractors may lead to an increase of fatal run-off-road accidents and accidents involving the hitting of animals, pedestrians or cyclists.” There have been extensive retrospective studies of the influence of ABS when fitted to other road vehicle types, particularly in the USA. (CEMA, 2013) cites (Kahane & Dang, 2009) and (Allen, 2010) and it is the information from these studies that appears to be referred to in the conclusion. (Kahane & Dang, 2009) provided the most recent review and update of this research as it relates to passenger cars. (Allen, 2010) provides one of the only studies specifically examining the effectiveness of ABS on heavy goods vehicles based on retrospective techniques. Both studies used sound retrospective analysis techniques and were funded by US government. (Kahane & Dang, 2009) reported on the long-standing history of analysis of the influence of ABS on accidents involving passenger cars, where the findings have fairly consistently been that ABS produces substantially beneficial reductions in some crash types but that these were offset by substantial increases in other types of crash such that the net overall effect was small. Depending on severity of collision, country of data and study techniques the net effect could be a slight improvement or worsening of the situation as attributable to ABS. Individual studies and authors often tried to explain these results with theories that might possibly explain them and these theories can sometimes be subsequently cited as facts. (Kahane & Dang, 2009) provide an excellent summary of the possible explanations put forward for the counter-intuitive results observed in studies of real world ABS on passenger cars, which is reinterpreted below:  Lack of driver knowledge of ABS: for example, a driver might take their foot of the brake when they feel the pedal vibration associated with ABS action.  Misperception of risk and/or risk compensation: Drivers may drive more aggressively because they perceive ABS will offer more benefit than it really can.

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 Longer stopping distances: for example, on loose surfaces once a vehicle has already left the road.  Drivers not sufficiently skilled to exploit the additional capabilities provided by ABS: for example, if a driver fails to see a stationary vehicle ahead until very late they might simultaneously brake and steer. Without ABS, the steering does nothing and they collide with the stationary vehicle. With ABS, the car swerves and avoids the collision but the driver does not modify the steering to a good avoidance course and leaves the road. This simultaneously reduces the frequency of a two-vehicle collision by one but increases run-off road collisions by one.  Flaws in the performance of early ABS technologies.  Confounding factors: All retrospective studies of this type measure association between variables and do not prove causation. Thus, it is possible that the observed increase in run-off-road collisions was not a consequence of ABS but of some other vehicle feature that was correlated with the fitment of ABS but was not accounted for in the analysis. For example, if vehicles equipped with ABS were on average more powerful, or attracted a riskier demographic of driver (e.g. ‘sportier’). (Kahane & Dang, 2009) reported that there had been comprehensive research into these theories and that little evidence was found to support any of them except the lack of driver knowledge of ABS. They report that NHTSA undertook several initiatives to improve driverDraft knowledge and a second round of retrospective analyses showed that the increase in fatal run-off road collisions had halved. However, there were methodological limitations to those studies and the main purpose of the 2009 study was to assess the long term effect once all of these variables had steadied and larger data samples were available. (CEMA, 2013) cited the results of (Kahane & Dang, 2009) as follows:  ABS has close to a zero net effect on avoiding fatal crash involvements.  ABS is relatively effective in helping to avoid nonfatal crashes, by reducing the overall crash involvement rate by 6 %.  However, at the same time, ABS can be causally linked to the rise of fatal run-off- road crashes of passenger cars which increased by a statistically significant 9 %. This figure increased to a statistically significant 34% on wet, snowy, or icy roads, where ABS is most likely to be activated. On these roads, all three types of fatal run-off-road accidents (side-impact with fixed objects, first event roll-over and all other run-off road crashes) increased significantly. For one type of accidents (side-impact with fixed objects) the observed increase was actually as high as 85%. The main results of (Kahane & Dang, 2009) are directly reproduced in Table 5.3. It can be seen that the figures (CEMA, 2013) cited are broadly correct but more detail is available. In particular, (Kahane & Dang, 2009) were still unable to explain the increases in run-off road collisions. However, since the introduction of ABS, the passenger car industry had built on the functionality offered by ABS to develop electronic stability control (ESC). This adds lateral acceleration, yaw rate and steering wheel angle sensors to an ABS system and when the sensors detect that the vehicle is not heading in the direction demanded by the driver input, it applies selective braking at individual wheels in order to help the driver achieve the desired path. So, (Kahane & Dang, 2009) analysed the effect of ABS and ESC in combination. The results are shown in Table 5.4.

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Table 5.3: Main results of long term study of passenger car ABS effect in the USA. Source: (Kahane & Dang, 2009) Positive estimate denotes a reduction in crash involvements with ABS; Yellow cells: Statistically significant estimates (at the one-sided 0.05 level)

Wet, snowy or icy All roads roads Cars LTVs Cars LTVs

All fatal involvements 1 -1 -1 -6 All run-off-road crashes -9 -6 -34 -10 Side impacts with fixed objects -30 None -85 -4 First-event rollovers -11 -10 -52 -31 All other run-off-road crashes -3 -5 -17 -3 Pedestrian/bicyclist/animal 13 14 None -14 Culpable involvements with other vehicles 4 -1 12 -6 Fatal Crash Involvements FatalCrash

All fatal involvements 6 8 16 14 All run-off-road crashes -1 11 -13 3 Side impacts with fixed objects -20 -9 -43 -15 FirstDraft-event rollovers 3 17 -12 6 All other run-off-road crashes 5 15 -3 9

Crash Involvements Crash Pedestrian/bicyclist/animal -8 -42 -8 -10

All Culpable involvements with other vehicles 17 20 37 36

Table 5.4: Effect of ABS and ESC in combination on passenger car fatal accidents (top) and all accidents (bottom). Source: (Kahane & Dang, 2009)

Percent reduction of fatal involvements Four-wheel ABS ESC Combined

Passenger cars All fatal involvements 1 14 15 All run-off-road crashes -9 36 30 Culpable involvements with other vehicles 4 19 22 LTVs All fatal involvements -1 28 27 All run-off-road crashes -6 70 68

Passenger car fatal accidentsfatal car Passenger Culpable involvements with other vehicles -1 34 33 Passenger cars All fatal involvements 6 8 14

All run-off-road crashes -1 45 44 Culpable involvements with other vehicles 17 13 28 LTVs Accidents

All All fatal involvements 8 10 17 All run-off-road crashes 11 72 75 Culpable involvements with other vehicles 20 16 33

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It can be seen that in combination, ABS and ESC offer substantial positive benefits in all categories of collision, fatal or otherwise, such that the combined total benefit would be greater than for ESC alone. ABS function is very closely associated with ESC. As a minimum, an ABS function must be incorporated when ESC applies selective braking because the ESC does not know the friction of the surface it is on and has no other way of ensuring the automatically applied braking does not lock a wheel thus worsening instability. ABS requires no additional hardware to ESC and does not, therefore, add significant cost compared with ESC alone. However, it should be noted that this analysis does not say whether the addition of ESC means that the specific accidents that ABS made worse would no longer be made worse, or merely whether the adverse effect of ABS remained but was outweighed by the benefit of ESC on separate crashes of the same category. In addition to these results, (Kahane & Dang, 2009) undertook a preliminary cost benefit analysis, for ABS alone, based on the simplifying assumption that ABS had zero effect not just on fatalities but also serious injuries (based on the theory that crashes with serious injury might share more characteristics with fatal crashes than with slight injury or damage only crashes). They found that the benefits of ABS on damage only and slight injury collisions was at least equivalent to the costs of mandating ABS on all passenger vehicles. The extent of research on HGV ABS is much less and so, (Allen, 2010) presents the results of a single analysis rather than a synthesis and update of many years of study. (CEMA, 2013) reports the results as follows:  A statisticallyDraft significant reduction of 6% was observed for crashes in which ABS is assumed to be potentially influential (relative to a control group).  Concerning involvement in fatal crashes, only a statistically insignificant 2% reduction effect was observed.  Among the types of crashes that ABS addresses, there was a reduction in jack- knife incidents and off-road overturns.  By contrast, an increase was observed in the number of accident involvements that would include the hitting of animals, pedestrians, or bicycles and – only in fatal crashes – rear-ending lead vehicles in two-vehicle crashes. Again, this is broadly accurate but omits some important details:  The estimate of 6 % reduction in crashes (all severities) where ABS was expected to offer a potential benefit translates to a 3% reduction in all crashes. Both of these results were statistically significant.  For fatal crashes, the estimates were 4% of ABS sensitive crashes, translating to 2% of all crashes, neither result being statistically significant.  Within these ‘net’ overall effects for fatal crashes, there was a: o Reduction in run-off-road overturn of 22.5% (statistically significant). o Reduction in jack-knife of 18% (statistically significant). o Reduction in ‘at-fault’ multi-vehicle collisions of 9% (statistically significant). o Increase in collisions with pedestrians, cyclists or animals of 9% (not statistically significant). o Increase in collisions where the HGV was the impacting vehicle in front to rear shunt collisions of 10% (not statistically significant).  ABS was found to be much more effective on wet roads than on dry roads. In the 7 US states analysed, crashes on wet roads represented 20% of the total.  The effectiveness of HGV ABS varied substantially by road type. It was much more effective on low speed roads (those with a speed limit <55 mile/h, or 88 km/h)

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than it was on high speed roads. In particular, ABS was less effective on true interstate routes (equivalent to Motorways in EU) compared with other high speed rural routes.  The report clearly highlights two methodological limitations that will result in the analysis under-estimating the effect of ABS. It analysed data from before and after the mandatory introduction of ABS and assumed ABS fitment was 0% in the before period and 100% in the after period. In reality, some vehicles will have been optionally equipped with ABS before the deadline and some will have had defective ABS after the deadline, reducing the difference in number of vehicles equipped. If 10% of vehicles were equipped voluntarily before the deadline and 4% were defective after, it would increase the estimate of effectiveness (all crashes) from 6% to 11%. In contrast to other vehicle types, ABS on motorcycles has generally been found to be highly effective in terms of real world crash reduction. (CEMA, 2013) cited an Insurance Institute for Highway Safety (IIHS) study showing a 37% reduction in risk of fatal crashes with motorcycle ABS and, as a European example, (Rizzi, Strandroth, Kullgren, Tingvall, & Fildes, 2015) showed a reduction in risk of fatal of 34% in Spain and 42% in Sweden. (CEMA, 2013) point to different characteristics of motorcycle braking and accidents as possible explanations for the difference, with strong justification. Effectively, the consequences of wheel lock on a motorcycle can be more severe than for 4-wheel vehicles. If a front wheel is locked it is very hard for the rider not to fall off the bike. Thus, riders tendDraft to under-use the front brake in order to avoid stability problems. Given relatively high load shift from rear to front under braking on a motorcycle, this can mean that the stopping distance is increased substantially from the optimum. ABS can give riders the confidence to fully exploit the brakes such that stopping performance can be substantially improved while also avoiding the instances of instability where riders do lock the wheels.

5.2.4 Extrapolating effectiveness estimates to EU collisions involving agricultural vehicles In their conclusions in relation to the effectiveness of ABS (CEMA, 2013) conclude that there will be no statistically significant reduction in accidents from the introduction of ABS on tractors. This has been shown to be correct for fatal accidents involving cars and trucks but not correct for fatal accidents involving motorcycles or non-fatal crashes involving cars trucks or motorcycles. (CEMA, 2013) also conclude that there is a significant risk that the introduction of ABS in tractors may increase fatal run-off road collisions and collisions with pedestrians, cyclists and animals. The evidence shows that:  Passenger car ABS reduces fatal collisions with pedestrians etc. but increases fatal run-off road collisions  HGV ABS decreases fatal run-off road collisions but increases fatal collisions with pedestrians etc. Thus, the two different vehicle types studied have opposing results in this respect, suggesting something in the vehicle performance or its usage characteristics are significantly different between passenger cars (CEMA, 2013) acknowledge the differences between motorcycles and passenger cars but not the difference between passenger cars and trucks or between agricultural vehicles and any of the other three road vehicle types. There are many factors that need to be considered when assessing the applicability of findings for the three road vehicle types to agricultural vehicles, including but not limited to:  Motorcycles and, in most cases, passenger car accidents do not involve towing of trailers. As such, only half of the 4 identified braking instabilities caused by locked wheels are applicable. On-road accidents involving agricultural vehicles often

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involve tractors towing trailers. As such, ABS can benefit all 4 identified braking instabilities and, in this sense, agricultural vehicles would be expected to behave more like the HGVs, where strong reductions in the incidence of jack-knife incidents were observed.  The research on HGVs found that there was a substantial difference in the effectiveness of ABS on high speed and low speed roads. Accidents involving agricultural vehicles more frequently occur on low speed roads.  Maximum speeds of road vehicles are all in excess of 110 km/h (bearing in mind US trucks are not subject to speed limiters as in Europe), the agricultural vehicles in the scope of this proposal have a maximum speed of just 60 km/h. This may influence consideration of the effectiveness on high speed roads.  The speed capability of cars trucks and buses has been well in excess of speed limits for a long period and can be considered constant over time. The sale of ‘high speed’ tractors has been increasing substantially in the last 10 years in several member states such that the speed capability of the agricultural vehicle fleet will have been increasing slowly over recent year and that increase will be expected to accelerate in future as sales continue to increase. Thus, predictions of the future benefit of mandating ABS on high speed tractors cannot be solely based on past data dominated by the accident patterns experienced by a fleet dominated by lower speed tractors.  The net casualty savings of ABS can be considered a product of the differing effects Draft in specific crash types, for example, for trucks the savings in jack-knife accidents versus the increase in pedestrian accidents. So, the net benefit depends on the fundamental distribution of different crash types in the absence of ABS. If accidents involving jack-knife were very rare and pedestrian crashes very common then you would expect ABS to give a substantial net increase in casualties. If the reverse were true you would expect a substantial net decrease in casualties. Agricultural vehicle accidents differ in the distribution of crash types compared with trucks, cars or motorcycles. Thus, exactly the same effects in specific crash types could produce a quite different net effect.  Geography – most of the studies referred to come from the USA and in the case of the truck study much data came from only 7 of the 50 States. Road geometries, traffic mixes, weather and a wide range of other parameters may differ significantly compared to the EU and, in fact, between different EU Member States. Thus, at worst the assumption that ABS in agricultural vehicles will have a zero net effect, the worst effect observed for passenger cars combined with the worst effect observed for HGVs and none of the beneficial effects observed for non-fatal collisions and motorcycles, is technically invalid. At best, it is just one of a range of possible outcomes, several of which may be considerably more beneficial.

5.3 Perception of benefits and impacts of implementing ABS on agricultural vehicles As part of the survey of stakeholders (see Section 1.2), information was sought on:  The perceived benefits of implementing ABS on agricultural vehicles.  The perception of accidents involving agricultural vehicles, with respect to possible causes and whether the impact, if any, that the implementation of ABS on agricultural vehicles might have on accident levels.  Alternative safety measures that might offer similar or greater safety benefits than the fitment of ABS to agricultural vehicles. It is recognised that any findings are based purely on subjective opinion; however it was considered that the results would still be of benefit/interest.

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5.3.1 Perceived benefits of ABS fitment Stakeholders were presented with a list of potential benefits and asked to identify those which they thought were applicable to the fitment of ABS. Figure 5.20 summarises the results.

30

25

20

15

10

Numberof respondents 5

0 Improved Improved Accident Other None Negative driveability stability avoidance benefits

FigureDraft 5.20: Perceived benefits of ABS fitment on agricultural vehicles

There were 39 responses in total. Improved vehicle stability was perceived to be most likely benefit, being selected by 27 respondents. Thirteen respondents considered that other benefits might result, including  Improvements in operation through the ability to include features such as hill hold/hill descent control, emergency brake assistance, coupling force control, and roll-over protection (by active braking of selected wheels).  Improved steerability.  Reduced tyre wear. Four respondents considered that there were no benefits to be gained from the fitment of ABS. Three respondents considered that there could be negative benefits associated with the fitment of ABS, namely that agricultural vehicle drivers might drive with less care and take greater risks, based on the perception that having ABS fitted made the vehicle safer to use.

5.3.2 Perceived impact of ABS fitment on accidents Stakeholders were asked to consider the possible causes of accidents involving agricultural vehicles by ranking the pre-defined causes listed below in terms of order of significance/importance (from 1 (most important) to 6 (least important)). Those possible causes listed under ‘other’ are those suggested directly by the survey respondents themselves.  Low agricultural vehicle speeds relative to other traffic on the road.  Poor conspicuity of agricultural vehicles, irrespective of the time of day.  Tractors turning across the carriageway to access side roads, field entrances, etc. and thereby turning across the paths of oncoming or overtaking vehicles.  Poor awareness of the size, speed and/or possible behaviour of agricultural vehicles and road layout, by other road users.

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 Poor braking performance of agricultural vehicles when preparing to turn or reacting to the movements of other vehicles.  Other, including but not limited to: o Agricultural vehicle use, e.g. high variance of tractor and trailer loads, poor tractor/trailer compatibility, or overloading. o Agricultural vehicle design, e.g. poor visibility within the immediate vicinity of the vehicle (front, side and rear), and (for SbSs and ATVs) cornering stability with respect to speed. o Agricultural vehicle condition, e.g. poor maintenance or lack of maintenance. o Human factors, e.g. driver age, general human error, poor judgement of speed differences between vehicles, tired (inattentive) agricultural vehicle drivers (due to long working hours), lack of concentration/experience by agricultural vehicle drivers (in comparison to drivers of heavy goods vehicles), lack of appropriate training for agricultural vehicle drivers, and (for SbSs only) a lack of knowledge of the vehicles. The responses received did not indicate a consistent or common rank ordering. However, based upon the average ranked importance (from 1 (most important) to 6 (least important)) the highest ranked possible causes were considered to be tractors turning across the carriageway (2.52) and poor conspicuity (2.64). Table 5.5 summarises the average rankings.Draft

Table 5.5: Assessment of the perceived ranking of possible causes of accidents involving agricultural vehicles (1 = most important, 6 = least important)

Poor Tractors Poor Poor Low speed Other conspicuity turning awareness braking Total number of 39 36 37 41 32 27 responses Total number of 5 3 4 7 4 8 unranked responses Total number of 34 33 33 34 28 19 ranked responses Average ranked 3.18 2.64 2.52 2.88 4.18 5.00 importance

Stakeholders were then asked to consider a number of criteria with regard to the implementation of ABS on agricultural vehicles, giving their opinion in terms of a score from 1-5 (None – Considerable) or ‘Unknown’. The criteria were as follows:  The extent to which ABS would reduce the likelihood of accidents when fitted to (a) agricultural tractors, (b) SbSs and ATVs, or (c) agricultural trailers and interchangeable towed equipment. The majority of respondents suggested that there would be no impact on the likelihood of accidents if agricultural tractors, agricultural trailers or towed equipment were fitted with ABS. In the case of SbSs and ATVs, the majority considered the impact to be unknown; where respondents did score the impact, this was ranked by the majority to be moderate for SbSs and none/moderate for ATVs. The full results are presented in Table 5.6.  The extent to which ABS would reduce the severity of accidents when fitted to (a) agricultural tractors, (b) SbSs and ATVs, or (c) agricultural trailers and interchangeable towed equipment.

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The majority of respondents suggested that there would be no impact on the severity of accidents if agricultural tractors, agricultural trailers or interchangeable towed equipment were fitted with ABS. The majority considered the likely impact upon SbS and ATV accident severity to be unknown; where respondents did score the impact, this was ranked by the majority to be moderate for both SbSs and ATVs. The full results are presented in Table 5.7.  The extent to which ABS would be beneficial to the safety of other road users when fitted to (a) agricultural tractors, (b) SbSs and ATVs, or (c) agricultural trailers and interchangeable towed equipment. The majority of respondents suggested that there would be no benefit to the safety of other road users if agricultural tractors, agricultural trailers or interchangeable towed equipment were fitted with ABS; for SbSs and ATVs, the majority considered the potential benefit to be unknown; where respondents did score the potential benefit, this was ranked by the majority to be moderate for both SbSs and none/moderate for ATVs. The full results are presented in Table 5.8.

Table 5.6: Assessment of the perceived extent to which fitment of ABS would reduce the likelihood of accidents (figure denote the percentage of respondents selecting a given scale of impact)

Scale of impact Vehicle type toDraft No of 1 3 5 which ABS is fitted respondents Unknown 2 4 (None) (Moderate) (Considerable) Agricultural tractors 46 10.9% 28.3% 23.9% 15.2% 15.2% 6.5% Side-by-Side vehicles (SbSs) 36 52.8% 16.7% 5.6% 19.4% 5.6% 0.0% (T3/T1) All-terrain vehicles 35 54.3% 17.1% 2.9% 17.1% 8.6% 0.0% (ATVs) (T3) Agricultural trailers 46 13.0% 26.1% 21.7% 13.0% 10.9% 15.2% Interchangeable 47 10.6% 29.8% 25.5% 23.4% 8.5% 2.1% towed equipment

Table 5.7: Assessment of the perceived extent to which fitment of ABS would reduce the severity of accidents (figure denote the percentage of respondents selecting a given scale of impact)

Scale of impact Vehicle type to No of 1 3 5 which ABS is fitted respondents Unknown 2 4 (None) (Moderate) (Considerable) Agricultural tractors 45 22.2% 24.4% 20.0% 11.1% 13.3% 8.9% Side-by-Side vehicles (SbSs) 34 50.0% 14.7% 11.8% 17.6% 2.9% 2.9% (T3/T1) All-terrain vehicles 32 53.1% 12.5% 9.4% 18.8% 6.3% 0.0% (ATVs) (T3) Agricultural trailers 48 16.7% 27.1% 16.7% 16.7% 6.3% 16.7% Interchangeable 48 16.7% 31.3% 16.7% 16.7% 12.5% 6.3% towed equipment

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Table 5.8: Assessment of the perceived extent to which fitment of ABS would be beneficial with respect to the safety of other road users (figure denote the percentage of respondents selecting a given scale of impact)

Scale of impact Vehicle type to No of 1 3 5 which ABS is fitted respondents Unknown 2 4 (None) (Moderate) (Considerable) Agricultural tractors 43 11.6% 30.2% 14.0% 20.9% 11.6% 11.6% Side-by-Side vehicles (SbSs) 32 53.1% 12.5% 9.4% 18.8% 6.3% 0.0% (T3/T1) All-terrain vehicles 31 54.8% 16.1% 3.2% 16.1% 9.7% 0.0% (ATVs) (T3) Agricultural trailers 47 10.6% 27.7% 14.9% 19.1% 19.1% 8.5% Interchangeable 46 10.9% 30.4% 17.4% 23.9% 15.2% 2.2% towed equipment

5.3.3 Alternative safety measures Stakeholders were also asked what alternative measures they considered might offer equivalent or greater safety benefits compared to the fitment of ABS. The responses are summarised inDraft Table 5.9. Whilst these alternative measures will not be included in the cost benefit analysis (see Section 8), Annex 1 discusses some of these measures in more detail and includes comments on potential costs.

Table 5.9: Alternative measures perceived to offer equivalent or greater safety benefits compared to the fitment of ABS, as suggested by stakeholders

Category Description Braking Technologies described in Regulation (EU) No 167/2013 and supplementing regulations Introduction of tractor-trailer braking compatibility corridors from Regulations (EU) 2015/68 and (EU) 2016/1788 Control of trailer braking system via drive-stick input (CVT transmission / vehicle travel speed control) EBS for trailers and ESC for towing vehicles Other vehicle controls V2V communications Improved recognisability of slow-moving or turning agricultural vehicles Vehicle distance control Horizontal acceleration sensing/vehicle stability control Other vehicle measures Seatbelts and roll-over protective structures (ROPS) Vehicle maintenance Improved maintenance & roadworthiness checks Vehicle conspicuity Improved lighting and signalling (Possibly also improved markings) Driver field of vision Improved field of vision for tractor driver (e.g. mirrors, cameras, blind spot proximity alarms) Camera systems for identifying OTHER road users when entering / crossing the carriageway Driver assist systems that actively warn or actuate to avoid a crash Surround sensing systems with autonomous vehicle interventions

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Category Description Driver training Improved driver training for tractor drivers Minimum driver age and/or licensing Improved driver training for OTHER ROAD USERS Safety of other road Minimum requirements for pedestrian protection users Mandatory helmets for T-category ATV users Enforcement measures Limiting allowed towed mass in relation to tractor mass Improved accident reporting Better police checking of on-road speeds

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6 Issues affecting the wider implementation of ABS systems on agricultural vehicles

6.1 Technical availability As discussed in Section 5.1, the generic ABS systems which are (currently) technically- available for use upon agricultural vehicles may be categorised according to the following characteristics:

 The medium used within the ABS control / modulating valve(s), (e.g. air, automotive-type brake fluid or mineral hydraulic oil).  The medium used to actuate the vehicle’s (foundation) brakes, (again either air, automotive-type brake fluid or mineral hydraulic oil).

The range of brake actuation systems / media typically employed on the agricultural vehicles considered by this investigation and the technical availability of suitable ABS systems for these applications are summarised in Table 6.1. The inherent characteristics of the generic ABS systems which are potentially suitable for interfacing with these agricultural vehicle brake actuation systems (see Table 5.1) may be summarised as follows:  PneumaticDraft ABS: A mature, truck-derived technology, which is readily-available and well-developed to suit the specific operational needs of agricultural tractors and associated (towed) vehicles. Installation requires certain pneumatic braking system components to be present on the vehicle (e.g. air compressor, storage reservoir(s), operator brake control valve). Some of these are often present on Category Tb vehicles, particularly if they are equipped to energise and control pneumatic braking systems on towed trailers and equipment (Figure 6.1). Pneumatic ABS is particularly suited to vehicles with pneumatic brake actuation, but can interface with hydraulically-actuated braking systems via Air-over- Hydraulic (AoH) converter units (see Section 5.1.1 and Figure 6.1). It can be particularly convenient if the vehicle utilises different brake actuation media on the front and rear axles (e.g. hydraulically-braked front axle / pneumatically- braked rear axle (Figure 6.2)). Unfortunately, current truck-derived AoH converter units are bulky and require considerable installation space (typically 3 required per vehicle – see Figure 5.3), but it is understood that considerably more compact designs are under development.

 Hydraulic (automotive-type brake fluid) ABS: These are believed to be derivations of automotive (e.g. car or light-medium truck) ABS systems. Unfortunately their limited fluid displacement capability restricts their brake actuation capability and potentially limits the maximum vehicle mass range to which they may be applied. This limits their suitability for larger (T1b) agricultural tractor applications. Nonetheless, these systems may well be suitable for other agricultural tractor categories (e.g. T4.3b, ATVs, SbS).

 Hydraulic (mineral oil) ABS: These systems are believed to have been specifically-developed for agricultural vehicle (tractor) applications, but they are currently understood to be at ‘Functional Prototype - High Level of Maturity’ or ‘Proof of Concept’ stages of product development (see Table 6.2). These ABS systems are specifically intended to interface directly with the hydraulic (mineral oil)-actuated service braking systems fitted to many tractors and self-propelled agricultural vehicles. However, they are not intended to operate in conjunction with hydraulically-actuated trailer or towed equipment braking systems. For tractor applications, such hydraulic ABS systems potentially require significantly

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less (total) system installation space, although certain components are believed to be of similar size to those of pneumatic ABS systems.

Table 6.1: Brake actuation systems typically used on agricultural vehicles and current technical availability of ABS systems for those vehicles

Vehicle Brake Actuation Comments re. Actuation System ABS technical availability? Type System / Medium Hydraulic (mineral System used on majority of T1b Yes – Systems exist but oil) tractors development ongoing Pneumatic + Found on certain vehicles – Rear axle Yes – Mature – In Hydraulic (mineral braked pneumatically – Front axle commercial use oil) braked hydraulically T1b Pneumatic + Usually only on higher-speed vehicles Yes – Mature – In Hydraulic (brake which utilise external ‘dry’ disc brakes commercial use fluid) Found on a minority of (mainly larger) Yes – Mature – In Pneumatic only tractors commercial use T2b tractors do not yet appear to be Hydraulic (mineral available. Installation space constraints Yes – Systems exist but T2b oil) likely to preclude use of other brake development ongoing Draftactuation mediums Hydraulic (brake Vehicle fitted with enhanced Yes – Mature – Vehicle can T4.3b fluid) – Servo- automotive-type ‘dry’ disc braking accept Light/ Medium assisted system on front & rear axles Truck system Yes – Proof-of-Concept exists but is believed to External ‘dry’ disc and/or internal Hydraulic (brake require further ATV multi-plate ‘wet’ disc brakes – fluid) development. Further Hydraulically-actuated commercial system due to be released in near future Yes – Proof-of-Concept Mainly hydraulically-actuated external Hydraulic (brake exists but is believed to SbS ‘dry’ disc brakes. Would accept fluid) require further automotive (car) type ABS solution development

Most common system for Vmax > 40 Yes – Mature –Truck- Pneumatic km/h, particularly on larger trailers trailer-derived system (MPMaxles ≥ 12000 kg) readily-available R3b / No – Small potential R4b Usually found on V ≤ 40 km/h max market unlikely to Hydraulic and/or smaller trailers stimulate system (MPM < 12000 kg) axles development Popularity dependent upon national Yes – Mature –Truck- market preferences. Also found on Pneumatic trailer-derived system large / heavy vehicles which (by readily-available definition) become Cat R S2b No – Small potential More common system for trailed market unlikely to Hydraulic implements, but less-suited to use at stimulate system V > 40 km/h max development

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AoH Converters for AoH Converter for Rear Axle Brakes Front Axle Brakes

Pneumatic Trailer Brake Valve & Couplings Draft Figure 6.1: Agricultural tractor pneumatic ABS system with hydraulic brake actuation via air-over-hydraulic (AoH) converter units. Pneumatic trailer braking control system also incorporated (Copyright Knorr-Bremse)

Pneumatic Actuators AoH Converter for for Rear Axle Brakes Front Axle Brakes

Figure 6.2: Similar agricultural tractor pneumatic ABS installation, but with hydraulic (AoH) actuation of front axle brakes and pneumatic actuation of rear axle brakes (Copyright Knorr-Bremse)

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6.2 Practical issues associated with ABS installation / implementation

6.2.1 Wheel speed sensor installation For ABS to operate effectively it must receive accurate data regarding the speed of the vehicle’s wheels, so that the sudden deceleration during braking of one or more wheels (impending wheel lock) may be detected and the appropriate reduction in braking effort instigated by the ABS control unit. On trucks, truck trailers and other on-road automotive vehicles, this is usually achieved by installation of electronic inductive-type sensors at the axle ends, which detect the rate of movement of a toothed exciter ring mounted inside the wheel hub (Figure 6.3). This type of installation works well for on-road vehicles and is widely-used with success on larger agricultural trailers / interchangeable towed equipment, which tends to be fitted with commercial vehicle-type axles.

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Figure 6.3: Inductive wheel speed sensor installation on a truck and/or agricultural trailer axle (Copyright Erentek Ltd)

Figure 6.4: Typical tractor stressed, cast chassis and axle configuration, with suspended front axle (Claas Axion 800 series) (Copyright Claas)

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However agricultural tractor axles are usually very different to those found on on-road vehicles. Rear axle assemblies normally comprise a rotating driveshaft supported by a part-oil-filled structural casting; these are attached to either side of the rear central transmission casting / assembly (Figure 6.4). Front axles are also usually rigid, cast housings with enclosed drive-shafts to each wheel end, where ‘king-pin’ swivel joints are provided to permit steering of the vehicle (see Figure 6.5 (left)). Front axle suspension is provided on limited number of tractor models by independent wheel-type systems (Figure 6.5 (right)), but suspended rigid-beam designs are by far the most numerous. As discussed previously, virtually without exception, Vmax > 40 km/h tractors feature both four-wheel drive (4wd) and front axle suspension, the latter being a mandatory requirement in certain EU Member States (see Section 3.4). Regarding ABS wheel speed sensor installation, the dilemma facing the tractor manufacturer is whether to install sensor exciter rings:

a) On the axle drive-shafts inside the part-oil-filled axle casings?

b) Externally at the axle / wheel ends within additional protective housings?

Approach (a) has much to recommend it, as the sensing components faces are protected from external (e.g. mud, water) contamination, but it requires initially-costly machining / modification of the axle casing to accept the sensors, the sensor entry point into the casing must be adequately sealed, and the external parts of the sensor body and the cable exit must be adequately protected. This approach has been used with success by the New HollandDraft ABS system (see Figure 5.3 and Figure 6.6). Some tractor manufacturers have raised concerns regarding the reliable operating temperature range and effective (oil) sealing of the inductive sensors in such installations, but current evidence does not appear to support these concerns.

Figure 6.5: Alternative designs of suspended front axle for agricultural tractors. Rigid beam (left) and independent wheel suspension (right) (Copyright Scarlett Research & Dana-Spicer)

Approach (b) requires the design and installation of bespoke housings / mountings at the axle ends of the tractor, both to support and to protect the sensors and associated exciter rings. Such installations undoubtedly face greater challenges in terms of contamination in off-road conditions but, realistically, are mechanical engineering challenges and they avoid the need to modify the axle housings of the vehicle: a possibly desirable scenario if ABS is an optional feature on a given vehicle model range. Currently both Fendt and JCB utilise this approach (see Section 5.1.1). It is worth noting that the majority of tractor manufacturers source 4wd front axles from a relatively small number of dedicated axle manufacturers (e.g. Carraro, Dana-Spicer, ZF). It would seem that, if ABS were to be mandatory, in order to reduce system cost (through volume manufacture), such axles could be supplied with wheel-speed sensors pre-installed.

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Figure 6.6: Wheel speed sensor installations on New Holland tractors fitted with ABS: front axle (left & centre) and rear axle (right) (Copyright CNH Industrial)

Regarding wheel speed sensor installation on agricultural trailers and towed equipment, as previously mentioned, the exciter ring component of such sensing systems (Figure 6.3) is already commonly installed on the commercial-vehicle axle designs frequently used on higher mass and Vmax > 40 km/h equipment. Due to higher production volumes worldwide, supported by the on-road sector, in many cases the purchase cost of such axles is lower Draftthan lower-specification versions intended for agricultural applications. However, whilst the exciter ring may be present on (commercial-type) axle, it is usually necessary to install the (relatively cheap) inductive-type sensors and associated cables: this reportedly adds ~€50 to the overall axle cost. Also, it should be noted that, irrespective of the number of axles on the trailer / towed equipment, it is normal practice to only sense the wheel speed of one axle, reducing the overall cost of sensor installation yet further. In the case of lower mass trailers / towed equipment which may currently use lower specification axles without the provision to readily-accept wheel speed sensors, ABS installation would potentially require the installation of higher-specification axles. Such axles are readily available on the market (with wheel speed sensors installed), but it is accepted that this would increase the overall cost of ABS installation on such lower mass vehicles. These factors have been considered by the Cost Benefit Analysis (see Section 8.3).

6.2.2 Vehicle braking system actuation In many respects this aspect determines the potential level of complexity of ABS system installation on agricultural tractors or trailers. As discussed in Section 6.1 (see also Table 5.1), the brake actuation system(s) present on the vehicle may influence the preferred choice of ABS type(s) for ease of installation, but this choice may be limited by current system availability / maturity (Table 6.2). Frequently alternative generic ABS systems may be fitted to a given vehicle model, but the installation complexity and overall system cost (system purchase cost + installation cost) may differ between system types. The current product maturity of pneumatic ABS systems has made them a popular choice amongst tractor and trailer manufacturers who offer ABS (see Table 5.2 and Table 6.1). If a tractor or trailer’s braking system is already configured for pneumatic actuation, the difficultly of installing a pneumatic ABS system is relatively limited. However, as highlighted in Section 6.1, the majority of current tractors employ hydraulic brake actuation systems and so, in the current absence of commercially-mature hydraulic ABS systems for agricultural tractors, or if both pneumatic and hydraulic brake actuation systems are present on the same vehicle, it is necessary to employ Air-over-Hydraulic

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(AoH) converter units to interface between the ABS and hydraulic brake actuation system (see Figure 6.1). Unfortunately current AoH converter designs are derived from the truck components and are bulky (Figure 6.7). Additionally, for a typical 4S / 3M tractor ABS system, three AoH units are required which, in total, can represent quite a packaging challenge on a modern tractor (Figure 6.8). It may seem difficult to believe but, particularly on larger, more complex tractors, component packaging space is at a premium. Engine exhaust emissions requirements have required the installation of both exhaust gas after- treatment equipment and additional tanks for diesel exhaust fluid storage. These requirements, together with the need to maximise diesel fuel storage capacity, so as not to restrict tractor daily working hours between refuelling, pose an ongoing challenge to the tractor designer. The prospect of having to accommodate three bulky AoH units, possibly at the expense of a reduction in fuel tank capacity, is understandably not a favoured option. Fortunately it is understood that more compact AoH converter designs are under development and, subject to market demand, are likely to be made available commercially. Draft

Figure 6.7: Current design of Air-over-Hydraulic (AoH) converter unit: main components (left) and installed on an agricultural tractor (right) (Copyright CNH Industrial)

Theoretically, the commercial availability of mature ABS systems, with the ability to interface directly with tractor service braking systems actuated hydraulically using mineral-based oil, would be a major advantage. However, the challenges these systems have to overcome, in comparison with hydraulically-actuated braking systems on automotive vehicles, which employ automotive-type brake fluid, are numerous:

 Fluid displacement for brake actuation: Automotive-type hydraulically- actuated braking systems (e.g. dry disc & caliper or dry drum systems) generally require limited fluid displacement volumes to apply the vehicle brakes. However, with certain exceptions (e.g. JCB Fastrac), hydraulically-actuated tractor brakes normally are of the single or multi-plate, oil-immersed type, applied by an annular piston. Brake application by this method requires a much greater volume of fluid to be displaced by the actuation system, effectively making the task of the ABS system more difficult. Consequently it has not been possible simply to transfer hydraulically-based ABS designs from the automotive sector, due to their limited fluid displacement capability. Rather it has been necessary to develop new ABS systems specifically to accommodate the larger fluid displacement requirements of hydraulically-actuated tractor braking systems.  Speed of response in cold temperatures: Currently the majority of hydraulically-actuated tractor service braking systems utilise the same hydraulic fluid as the other hydraulic services on the vehicle. This is usually also the transmission / rear axle lubricating oil: consequently it is usually of higher

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viscosity than automotive-type brake fluid and is also more subject to viscosity increases at lower temperatures. ABS inherently needs the brake actuation system to respond rapidly to modulation signals generated by the ABS control module in order to operate effectively. This is a recognised issue and the hydraulic (mineral oil) ABS systems currently under development are understood to be addressing it.

7 2

3 8 4

1 Draft 3 6 5

Figure 6.8: Braking system installation (featuring Air-over-Hydraulic (AoH) ABS) on New Holland T7 Heavy Duty tractors: system components shown in yellow (1) air compressor, (2) air processing unit, (3) air reservoirs, (4) pneumatic foot brake valve, (5) ABS control module, (6) air-hydraulic converter units, (7) pneumatic trailer brake control valve, (8) pneumatic trailer braking system couplings (Copyright CNH Industrial)

6.2.3 ABS control strategy development and implementation It has often been said that “tractors are not trucks” and few would question the logic behind this statement. However, as highlighted by this report, agricultural tractor-trailer combinations do perform on-road transport operations at total / gross vehicle masses equivalent to large truck-trailer combinations. The logic behind the application of truck- type ABS technology to agricultural tractors and trailers is therefore also valid. However, whilst ABS hardware may be transferred to agricultural vehicles, with certain adaptations, truck-type ABS control strategies (software) could not be transferred with similar ease. The specific nature of agricultural tractors, their multiple loading configurations, the split between on-road and in-field operation and the frequent presence of intelligent driveline control systems on the vehicle, required the development and refinement of ABS control software and systems to provide acceptable and reliable levels of performance. This has required considerable effort and investment; both on the part of braking equipment suppliers and also the small number of tractor manufacturers who have chosen to implement ABS technology (see Section 5.1.1). Whilst trailer / trailed equipment manufacturers have been, in the majority of instances, able to utilise off-the-shelf ABS systems derived from truck-based products (operating on 12 volt as opposed to 24 volt power supply), tractor manufacturers found that a range of issues required addressing. These included the following:

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 Effective sensing of vehicle speed: This is a pre-requisite for effective ABS operation. However, despite the provision of speed sensors on all wheels, the pioneering implementers of agricultural tractor ABS have apparently encountered difficulties in ensuring reliable vehicle speed data is obtained at all times. Factors such as the larger rolling circumference of tractor tyres (compared with those of trucks) and also the normal practice to engage the vehicle’s four wheel drive (4wd) system during braking, have possibly contributed to this issue. The problem appears to have been largely addressed by the incorporation of a vehicle acceleration sensor (accelerometer) within the ABS control module. Modern designs of ABS control modules for on-road truck-trailer installations apparently incorporate this feature to enable the roll stability of the vehicle to be controlled by active braking of certain of the vehicle’s wheels. The utilisation of this type of ABS module on agricultural tractors, together with further bespoke control software development, seems to have overcome the problem.  Interaction with vehicle driveline / transmission control systems: As mentioned above, as a distinct departure from on-road vehicle control methods, it is normal practice for the 4wd system of a tractor to be engaged during vehicle braking. Originally this was done to provide braking effort (via the 4wd driveline) on the otherwise unbraked tractor front axle. Today most Vmax > 40 km/h tractors fit brakes on their front axles, but generally these are of lower capacity than those fitted to the rear axle; consequently the practice of 4wd engagement on braking is retained. As can be imagined, this poses intriguing control issues for the ABS control Draftsoftware, but appears to have been addressed with considerable success. Additionally, the majority of current agricultural tractor models offered with ABS are fitted with continuously-variable transmissions (CVTs); indeed, such transmissions are present on an increasing proportion of > 200 hp (> 150 kW) tractors, which themselves are most likely to have Vmax > 40 km/h capability. CVT transmissions are controlled by intelligent vehicle software, usually in conjunction with engine speed and power output. Consequently, tractor manufacturers found it necessary for the ABS system to control both the vehicle’s brakes and the transmission (and engine) during ABS operation, to ensure one system was not fighting against the other in an undesirable manner. To achieve this it was necessary for the tractor engine-transmission control system to communicate with the ABS control system and vice-versa. Again, an issue which has been addressed successfully, but by no means a small task.  Off-road vehicle braking behaviour: The issues surrounding the potentially undesirable effects of ABS on vehicle off-road stopping distances have been discussed in Section 5.2.2. Whilst it is widely accepted that ABS potentially improves the on-road braking performance of a vehicle, it can in certain instances detract from off-road braking performance and result in longer stopping distances in such conditions. When operating off-road on loose soil or gravel-type tracks, shorter stopping distances can result from disabling / switching-off the ABS system and permitting the wheels to lock during braking, whereby a ‘wedge’ of material builds up in front of the locked wheels, helping to decelerate the vehicle. Directional control of the vehicle is of course lost during such ‘wedge braking’, but it is claimed that a shorter stopping distance is a worthwhile trade-off. This is a familiar issue for ABS manufacturers as is applies to vehicles (mainly construction trucks) used in both on and off-road conditions. Consequently current tractor ABS systems have been configured to provide a range of different operating characteristics to best-suit the prevailing operating conditions. The specific solutions are as follows:- o ‘On-Road’ ABS operating mode: When stopping from speed (V > 40 km/h), vehicle brake application pressure is modulated to prevent wheel-locking and to maintain vehicle directional control. However, even when operating in this ‘on-road’ mode, the ABS modulation is de-activated when the vehicle speed

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reduces below a pre-determined (customer-selected) threshold (e.g. 5, 8 or 12 km/h), below which wheel-locking (and wedge-braking) are permitted. o ‘Off Road’ ABS operating mode: An in-cab switch enables the driver to select ‘off-road’ ABS mode (Figure 6.9). Above ~40 km/h ABS behaviour is identical to the ‘on-road’ mode, but as speed reduces into the 40 > V > 15 km/h range, the ABS software permits a more aggressive, selective-wheel-lock, ‘deep-cycle’ brake control mode. Finally, when V < 15 km/h, wheel locking is permitted to maximise any ‘wedge braking’ benefits. Should the operator attempt to drive above 40 km/h in ‘off-road’ mode, the vehicle is either prevented from exceeding 40 km/h or the ABS automatically defaults to ‘on-road’ mode. This threshold could, of course, be set at an alternative value during system programming.

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Figure 6.9: ABS system switchable ‘Off-Road’ operating mode (Copyright Knorr-Bremse)

It therefore appears that braking system manufacturers have gone to some lengths to develop a range of speed-dependent ABS operating strategies to address concerns regarding off-road braking behaviour of ABS-equipped vehicles, with the objective of satisfying the dual objectives of maximising vehicle braking performance and retaining vehicle directional control. Two of the three agricultural tractor manufacturers which currently offer ABS (see Section 5.1.1) provide an operator’s switch to disable the system for off-road operation, if so desired. However, the system is automatically re-enabled above a certain threshold forward speed.

6.3 Potential benefits of ABS installation / implementation on agricultural vehicles This investigation has primarily focussed upon the potential improvements in vehicle braking performance and the associated cost and manufacturing complexity issues which may result from ABS installation upon agricultural vehicles. However, there are a range of additional benefits which can potentially be realised once a vehicle (tractor) is fitted with ABS. Essentially a modern, multi-facetted ABS system permits control of the vehicle’s braking system to be effected via vehicle control software. Given the wide range of vehicle sub-systems already controlled by intelligent software on larger agricultural tractors, this potentially enables integrated control of the vehicle’s driveline to achieve greater functionality. Some of the options explored (and in certain cases realised) to-date include:

 Automatic brake application (Hill-Holding): To assist vehicle hill starts. The tractor’s brakes continue to be applied, automatically, when the driver’s foot is removed from the brake pedal, until the clutch pedal is released sufficiently for

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the engine-transmission to prevent the vehicle rolling backwards. However, this feature is only of real benefit on tractors equipped with stepped-ratio (Powershift) transmissions, because those fitted with CVT transmissions automatically provide this functionality via the engine-transmission control system.  Intelligent tractor steering brake control: (Figure 6.10) Marketed by New Holland as the ‘ABS SuperSteer’ system. Conventional tractor braking systems require the driver to press the ‘independent’ left or right brake pedals to operate the rear wheel brakes individually to assist tight-radius turning at field headlands. The ABS SuperSteerTM system either (a) operates the inner rear wheel brake automatically as the steering wheel is turned (in response to front wheel steering angle), or (b) conventionally by operator control via the independent brake pedals. However, in both instances the speed of the inner wheel is monitored by the ABS system and brake pressure is controlled to ensure the wheel is not over- braked, does not skid and so does not damage the field surface: a particularly important issue on grassland. Draft

Figure 6.10: New Holland ABS SuperSteerTM system. Traditional in-field headland turning by use of independent rear wheel brake pedals (left) and automatic ABS- controlled independent rear wheel brake operation (right)

(Copyright CNH Industrial)

 Traction control: On certain on-road vehicles, independent, intelligent control of the wheel brakes is employed to maintain / enhance vehicle traction in conditions of poor tyre-ground surface adhesion. However, agricultural tractors have been designed from a very early stage to operate effectively in conditions of poor or uneven traction. To achieve this they are fitted with 4wd systems and differential locks on both the front and rear axles. It is common practice on medium / large tractors (>125 hp / 93 kW) to engage / disengage either or both of these systems automatically and/or intelligently, depending upon vehicle steering angle, forward speed and even wheelslip level. Consequently, with such functionality already present on the vehicle, the additional traction control features which may be provided by an ABS system at anything other than higher on-road operating speeds, are likely to be limited.  Intelligent trailer braking control: When operating an agricultural tractor and trailer combination, it is desirable that the braking systems of each vehicle generate sufficient braking effort to bring the combination to a controlled stop whilst under complete control. In order to do this, each vehicle must generate braking effort proportional to the loads being carried by its axles but, unfortunately, the magnitudes of these loads change regularly, many times during the working day, depending upon whether the trailer is laden or unladen. As (common) rigid drawbar / unbalanced trailers also transfer a proportion of their loading onto the tractor (see Section 2.3.6), the tractor’s braking system is also required to deliver varying levels of performance. This is a widely-recognised issue

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and various approaches have been implemented to address it, the most common being the installation of a load sensing valve on the trailer’s suspension system (Figure 5.6), to vary the vehicle’s braking effort in relation to the load being carried. However, the characteristics of the robust mechanical suspension systems frequently fitted to agricultural trailers / towed equipment often cause the effectiveness of such devices to be compromised. For the first time in EU legislation, Regulation (EU) 2015 / 68 (European Union, 2015) introduced mandatory ‘compatibility corridors’ for agricultural vehicle braking performance, to try and improve the balance of braking between the towing and the towed vehicle. This is undoubtedly a good move, but the ultimate level of improvement gained will be dependent upon the capabilities of the braking hardware employed. Intelligent trailer braking control systems permit the braking effort of the trailer to be varied in relation to that of the tractor, by use of an electronically-controlled tractor-trailer brake control valve mounted on the tractor. This provides a greater range of system operating characteristics, which can be configured to operate more closely in relation to the tractor’s braking behaviour, in response to data input from vehicle-mounted accelerometers and wheel-speed sensors. Potential benefits include: i) Trailer brake control in response to tractor engine braking / CVT driveline braking or use of the tractor’s exhaust brake (if fitted); ii) Improved tractor-trailer coupling force control during braking, thereby Draftreducing the risk of jack-knifing. It may be questioned how these functions are related to ABS. Simply that if ABS is already installed upon the tractor and an EBS (Electronic Braking System) is fitted to the trailer (to provide ABS functionality), the wheel speed sensors, vehicle accelerometers, communication and control hardware will already be present to support an intelligent trailer braking control system.  Vehicle stability control: This is also primarily of benefit to tractor-trailer combinations, particularly those vehicles with higher Centre-of-Gravity (CoG) locations (e.g. forage wagons, high-sided trailers) and/or those frequently used on steeply sloping ground. Automatic application of one or more individual wheel brakes, in response to vehicle acceleration and speed input data, can be used to stabilise the vehicle whilst cornering and undertaking other manoeuvres. Again, the intelligent vehicle braking system control capability present in an ABS can provide a platform for such enhanced functionality on the vehicle.  Tyre wear reduction: As commented previously, the performance of load sensing systems on agricultural trailer / towed equipment fitted with mechanical suspension systems is frequently sub-optimal. This can result in ‘over-braking’ of the vehicle whilst unladen or part-loaded, causing wheel-locking / skidding and excessive trailer tyre wear. It is common practice for large trailers and towed equipment to be fitted with large and expensive (~€500 each) ‘flotation’-type tyres to minimise in-field soil compaction. Whilst not a substitute for a load- sensing braking system (which is in any case a mandatory requirement on Vmax > 40 km/h trailers and towed equipment), ABS can reduce the likelihood of trailer wheel locking during braking and thereby extend tyre life. With four or six tyres on a tandem or tri-axle trailer, the saving in tyre replacement costs alone can potentially justify the investment in ABS technology.

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6.4 Practical availability and economic availability Given the apparent ready-availability of pneumatically-based ABS systems for use on agricultural tractors and trailers / towed equipment, the practicality and economic feasibility of their installation is, in practice, determined by a range of factors, including:

 The brake application method / medium used on the vehicle.  The available space for ABS component installation.  To a lesser extent, the availability of a pneumatic braking system on the vehicle (tractor), either for the target vehicle or for trailers / interchangeable equipment towed by it. Such systems are highly likely to be present upon Tb (Vmax > 40 km/h) tractors which, as previously discussed (see Section 3.3.1), are almost certainly to be of ≥ 130 hp (≥ 97 kW) rated engine power.

The situation regarding ABS installation on agricultural trailers and interchangeable towed equipment (Category R and S) is relatively clear-cut. ABS installation on pneumatically-braked vehicles presents few challenges, given the presence of (or feasibility of installing) suitable wheel speed sensors. If the vehicle is designed from the outset for Vmax > 40 km/h use, this is unlikely to be an issue (see Section 6.2.1). Mature pneumatic ABS systems are readily-available at reasonable cost (~€500 OEM cost for a basic system (Figure 5.6)) and they may be installed without difficulty. More complex (and capable) EBS systems are also available (Figure 5.7), but at greater cost. However, ABS systems areDraft not currently available for hydraulically-braked trailers (Table 6.1 and Table 6.2) but, as discussed previously (see Section 5.1.2), hydraulic braking systems are unlikely to be fitted to Vmax > 40 km/h trailers / towed equipment. Pneumatically-based ABS technology is readily available for use on agricultural tractors (e.g. T1b) but, due to the bespoke nature of the target vehicle, it may well be necessary to approach ABS installation on a model-range by model-range basis. The system configuration and/or installation approach which may be suitable for one model range may be entirely unsuited to another. Whilst this does not necessarily increase the base- cost of the ABS hardware to the vehicle manufacturer, it may substantially increase the installation and bespoke development costs which must be incurred in order to provide ABS, thereby potentially increasing system cost to the vehicle user. The factors highlighted at the beginning of this section are likely to influence the preferred choice of ABS system for ease of installation on agricultural tractors, which in turn may be limited by current system availability / maturity (see Table 6.1 and Table 6.2). Frequently, alternative generic types of ABS system may be fitted to a given vehicle model, but the installation complexity and overall system cost (system cost to the OEM + installation cost + development cost) may differ between the ABS types. It has not been possible for this investigation to quantify and report the potential overall system costs for reasons of commercial confidentiality, but ABS suppliers have commented that, depending upon production volumes, system costs to OEMs may be in the region ~€1000 – 1300. Where offered as optional equipment, tractor manufacturers currently retail ABS at ~€4000 – 5000. Installation of pneumatic ABS systems may be more challenging on smaller / lower- power vehicles, due to space and other engineering constraints. Also, ABS cost remains largely the same although the retail price of smaller vehicles is substantially lower. Fortunately, such vehicles are not typically offered with 40 < Vmax ≤ 60 km/h capability. Study of the current European agricultural tractor designs (Scarlett, 2013) suggests that rated engine power and vehicle size (Max Permissible Mass (MPM)) can provide relatively clear threshold levels below which T1 tractors with 40 < Vmax ≤ 60 km/h capability are not offered (see Section 8.2). The pioneering tractor manufacturers who already offer ABS (see Section 5.1.1) have, without doubt, incurred substantial system development costs, but have undertaken these activities as a commercially-orientated activity, no doubt in conjunction with

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6.5 Summary Based on the information presented in the previous Sections, Table 6.2 summarises the current availability of ABS systems for agricultural vehicles in terms of a Technology Readiness Stage (TRS) based approach, whereby the different stages are as follows:

 TRS01: Concept ABS technology  TRS02: Functional prototype ABS technology with low degree of maturity  TRS03: Functional prototype ABS technology with high degree of maturity  TRS04: Market ready ABS technology – ready for/in early stages of introduction to market  TRS05: Readily available ABS technology, proven in the market

Whilst it was originally proposed to consider the practical applicability and economic feasibility of the systems using a similar approach, the assessment has highlighted that this will vary, particularly in the case of agricultural tractors, on a model-to-model basis, due largely to the brake application method / medium used on the vehicle and the available space for ABS component installation. As such, a useful categorisation by vehicle category cannot be achieved.

Table 6.2: GenericDraft ABS systems potentially suitable for use on agricultural vehicles ABS Type (System Vehicle Vehicle Brake Actuation Current Technology Modulating / Control Type Medium Readiness Stage (TRS) Medium)

Pneumatic Pneumatic TRS05

Hydraulic (mineral oil) Pneumatic TRS05 T1b / T2b TRS02 or 03 depending Hydraulic (mineral oil) Hydraulic (mineral oil) on system

Hydraulic (brake fluid) Pneumatic TRS05

TRS04 or 05 depending T4.3b Hydraulic (brake fluid) Hydraulic (brake fluid) on system TRS01 or 04 depending ATV Hydraulic (brake fluid) Hydraulic (brake fluid) on system TRS01 or 04 depending SbS Hydraulic (brake fluid) Hydraulic (brake fluid) on system

Pneumatic Pneumatic TRS05 R3b / R4b Hydraulic Hydraulic ABS not available

Pneumatic Pneumatic TRS05 S2b Hydraulic Hydraulic ABS not available

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7 Possible alternative criteria for ABS implementation The current text of Regulation (EU) 2015/68 (European Union, 2015) uses agricultural vehicle max design speed (Vmax) as threshold criteria for the mandatory implementation of ABS. As discussed in Section 1.1, vehicles of Categories Tb, R3b, R4b and S2b of

Vmax > 60 km/h are required to be fitted with ABS. Additionally, unless the text of the regulation is amended, ABS will also become mandatory on Category Tb tractors of st st 40 < Vmax ≤ 60 km/h from 1 January 2020 or 1 January 2021 onwards (new types or new vehicles, respectively).

Vmax is in many respects an appropriate criterion for ABS implementation, being directly related to the likely Kinetic Energy (K.E.) of a vehicle in motion and the consequent loading placed on the vehicle’s braking system during deceleration. However, as discussed in Section 2, Categories Tb, Rb and Sb potentially encompass a very wide range of vehicles, some of which may not necessarily readily-accept or indeed require the implementation of ABS technology. Vehicle mass is another promising criterion, combining as it does with velocity to determine vehicle Kinetic Energy and braking system load. Historically, vehicle (maximum / gross) mass has been employed in the national legislation of certain EU Member States to target the implementation of ABS upon on-road vehicles. Regulation (EU) 167/ 2013 states that agricultural vehicles of Vmax > 40 km/h shall meet an equivalent level of functional safety, with regard to brake performance and, where appropriate, Draft anti-lock braking systems, as motor vehicles and their trailers. Consequently, the possibility of employing vehicle mass as an additional criterion, alongside Vmax, is perhaps worthy of further investigation, in order to ensure that ABS technologies are indeed targeted towards agricultural vehicles “where appropriate”. There is possibly considerable merit in restricting the imposition of ABS to larger, more powerful vehicles which are likely to undertake the majority of agricultural transport operations. As discussed in Section 3.2, the availability and usage Vmax > 40 km/h is very much restricted to vehicles of > 130 hp (97 kW) rated engine power and tractors in the 151-230 hp and 231-320 hp categories were found to perform the majority of ‘Material Transport’ operations (Figure 3.11), working in conjunction with agricultural trailers of

10-14 tonnes and 14.1-17 tonnes carrying capacity (~11,000-13,900 kg MPMaxles). Trailer carrying capacity and consequent Total (Gross) Mass effectively dictates the power rating and consequent size of tractor required for effective tractor-trailer transport operation at V > 40 km/h. The power:mass ratio of the combination, particularly in relation to the higher levels of on-road rolling resistance generated by tractor and trailer tyres, essentially dictates if higher speeds are achievable when laden. Figure 7.1 presents the likely variation in the operating / gross mass of V > 40 km/h tractor and trailer combinations (N.B. rigid drawbar / unbalanced trailer) with tractor engine power. Study of vehicle data has shown that, when attached to an appropriately- sized (laden) rigid drawbar-type trailer, the tractor’s operating mass (sum of axle masses) is likely to equal / approach the vehicle’s Maximum Permissible Mass (MPM). Consequently the Total (Gross) Mass of a 200 hp tractor + trailer combination is likely to be approximately 30,000 kg. Vehicle specification data shows that the maximum permissible mass (MPM) of Category T1 tractors correlates strongly with vehicle rated engine power (Figure 7.2). This is of little surprise as larger, more powerful tractors are required to operate larger, heavier attached (mounted) implements and so need greater payload capability. This quantity, in conjunction with vehicle unladen mass, effectively determines the vehicle’s maximum permissible mass.

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Draft Figure 7.1: Likely variation of tractor-trailer combination gross mass with tractor engine power

Figure 7.2: Relationship between T1 tractor maximum permissible mass and rated engine power Source (Scarlett, 2015) & (Scarlett, 2016)

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A direct correlation also exists between the sum of technically-permissible mass per axle (MPMaxles) of an agricultural trailer and its carrying capacity (Figure 3.19 and Figure 7.6). Both the R3b and S2b categories embrace an extremely wide range of vehicle sizes and build-complexity; in some cases greatly increasing the cost, difficulty and even the feasibility of ABS installation (see Section 6). However, agricultural trailers / towed equipment do not operate in isolation, but rather only when used in combination with a tractor. Consequently, when assessing likely risk to other road users, the ‘worst-case’ vehicle configurations are:

i) Solo-Tractor with mounted implement(s), operating at a mass close to max permissible mass.

ii) Tractor + fully-laden Trailer combination.

Figure 7.3 illustrates the variation in kinetic energy of these vehicle configurations with tractor rated engine power (equivalent to vehicle size) over the 40 < Vmax ≤ 60 km/h speed range currently under consideration for mandatory ABS installation.

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Figure 7.3: Variation of tractor and tractor + trailer kinetic energy with tractor size (rated engine power) and forward speed

Figure 7.4 presents the same agricultural vehicle data, but also illustrates the kinetic energy levels of trucks of a range of different masses (7.5, 12, 20 and 40 tonnes), each travelling at a nominal speed of 60 km/h. It will be noted that the K.E. of a solo tractor of > 175 hp potentially equates or even exceeds that of a 12,000 kg gross mass truck: virtually all Vmax > 40 km/h tractor-trailer combinations would also exceed this K.E. level, irrespective of their actual speed of travel above 40 km/h.

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Draft Figure 7.4: Comparison of kinetic energy levels of agricultural tractors and tractor + trailer combinations with those of trucks travelling at 60 km/h

If travelling at V ≥ 50 km/h, most tractor-trailer combinations of > 175 hp (> 130 kW) tractor size (i.e. Lower Middleweight 6 cylinder vehicle and larger (Figure 7.2)) would exceed the K.E. of a 20,000 kg truck travelling at 60 km/h; whereas a ~300 hp (225 kW) tractor plus R4 trailer combination would effectively be equivalent to a 40,000 kg (articulated truck & trailer) vehicle at comparable travel speeds. Figure 7.5 presents an entirely theoretical concept of implementing a (tractor) max permissible mass threshold of MPM ≥ 11,500 kg. Vehicles of this size and larger would be required to fit ABS if their Vmax > 40 km/h, whereas those of lower mass would not require ABS unless their Vmax capability exceeded 60 km/h. This potentially generates the following benefits:

 ABS would only be required on larger, more powerful tractors (typically > 175 hp (130 kW)) in the 40 < Vmax ≤ 60 km/h range. These higher-powered vehicles are those most likely to be capable of towing heavier trailers / towed equipment at speed. They also are more expensive and more complex and so could support the undoubted additional cost of ABS more readily.

 Smaller / lighter / cheaper T1 tractors and also (possible future) T2b models would not have to be subjected to the possible burden of mandatory ABS.

 Implementation in this manner would ensure an equivalent level of agricultural tractor (braking system) performance and safety to that of ≥ 12,000 kg trucks.

Figure 7.6 presents a similar concept for agricultural trailers and interchangeable towed equipment. The proposed threshold would result in ABS being mandated only on R3b and

S2b vehicles of 40 < Vmax ≤ 60 km/h and MPMaxles ≥ 12,000 kg, whereas lower mass examples would not require ABS unless Vmax exceeded 60 km/h. Category R4 vehicles would of course require ABS if Vmax > 40 km/h.

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Draft Figure 7.5: Possible maximum permissible mass (MPM) threshold value (≥ 11,500 kg) for the introduction of ABS on 40 < Vmax ≤ 60 km/h Category T1 tractors

Figure 7.6: Possible maximum permissible mass (MPMaxles) threshold value (≥ 12,000 kg) for the introduction of ABS on 40 < Vmax ≤ 60 km/h Category R3 and S2 vehicles

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The possible benefits of this approach are that ABS would only be required on larger, more expensive trailers (typically >10,500 kg carrying capacity (rigid drawbar-type)) which are more likely to be fitted with higher-specification (pneumatic) braking systems and axles which will readily accept wheel speed sensors. Consequently, the cost and complexity of ABS installation would be significantly lower (see Section 8.3). Smaller (3500 < MPMaxles < 12,000 kg) R3b trailers and numerous S2b towed equipment would avoid the burden of mandatory ABS and thereby avoid the imposition of greater costs on users. It should be noted that the aforementioned alternative implementation criteria are only concepts, but they are evaluated fully, alongside other possible policy options, by the Cost Benefit Analysis (see Table 8.1).

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8 Cost benefit analysis

8.1 Overview of CBA methodology The cost benefit analysis is intended to be suitable to inform a European Commission Impact Assessment, should this be carried out, in accordance with the guidelines laid down for these (European Commission, 2009)7. The aim has been to define the most promising policy options and to study their effects over a defined evaluation period, in this case for a period of 15 years from the date the measure would be expected to come into force. As far as possible, the costs will be identified for each year of the study, in terms of the increase in retail cost of an agricultural vehicle as paid by the end consumer (the farmer). Similarly, the benefits for each year of the evaluation period will be estimated and, wherever possible, monetised. A cost benefit ratio has been calculated from the total benefits over the evaluation period, divided by the total costs. This has been repeated for each policy option. The agricultural vehicle market is relatively diverse across Europe and data recording is non-uniform. Thus, there is much that remains unknown that has to be estimated or excluded from consideration. The study has used the best information that can be derived, bearing in mind the need for proportionality in the time and cost required to undertake the assessment.

8.2 Development of CBA scenarios Guidelines suggestDraft that Impact Assessments should identify a ‘do nothing’ option which documents what would happen if the Commission did not intervene in the market. At least one ‘do something’ option should then be defined and the impact of doing something is measured as the difference between the two options. It is usual that the ‘do-nothing’ option is effectively equivalent to ‘business as usual’. That is, the free market evolves in accordance with market forces. The baseline condition therefore, typically involves simple forecasting of recent trends, with consideration for other policies already implemented but excluding the effects of other new policies not yet implemented. The ‘do something’ option usually represents a regulatory intervention that might, for example, involve making some form of minimum standard mandatory. This involves introducing step changes in the market. The case specifically assessed in this report is unusual in this respect because, if the Commission now choose to implement the ‘do nothing’ option, then an existing timed clause in an existing Regulation will enter into force and require mandatory fitment of ABS to agricultural tractors with a maximum speed capability between 40 and 60 km/h. Thus, doing nothing will see a substantial change compared with business as usual. The first ‘do something’ option would revoke this new requirement such that ABS did not become mandatory on those tractors. Effectively, this would be the only option that would see the market evolve freely in a ‘business as usual’ manner. Thus, this is the option that forms the baseline for the purposes of forecasting and care is required in the interpretation of costs and benefits. For example, when considering option 1 relative to option zero, the ‘benefit’ of the option would be a reduction in costs and the ‘cost’ would be a reduction in the economic benefit of casualty reduction expected. Again, this is the opposite to normal expectation and indeed some other options within this study. Standard terminology has been modified where possible to try to avoid confusion. The options identified are reproduced in full in Table 8.1.

7 Available from http://ec.europa.eu/smart-regulation/impact/commission_guidelines/docs/iag_2009_en.pdf

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Table 8.1: Proposed policy options for assessment

Option Scenario type Outcome (Tractors) Outcome (Trailers) Do nothing ABS on all Category Tb tractors, 0 No ABS on trailers, 40 < Vmax ≤ 60 km/h (Tractor ABS only) 40 < Vmax ≤ 60 km/h No ABS on any Category Tb tractors, 1 No ABS No ABS on trailers, 40 < Vmax ≤ 60 km/h 40 < Vmax ≤ 60 km/h Partial ABS No ABS on any Category Tb tractors, ABS on Category R3b / R4b trailers, 2 (Trailer only) 40 < Vmax ≤ 60 km/h 40 < Vmax ≤ 60 km/h Partial ABS No ABS on any Category Tb tractors, ABS on Category R3b trailers, MPM ≥ 3 axles (Larger Trailer only) Draft40 < Vmax ≤ 60 km/h 12,000 kg and R4b trailers, 40 < Vmax ≤ 60 km/h Full ABS ABS on any Category T1b tractors, ABS on Category R3b/R4b trailers, 4 (Tractor + Trailer) 40 < Vmax ≤ 60 km/h 40 < Vmax ≤ 60 km/h Partial ABS ABS on any Category T1b tractors, ABS on Category R3b trailers, MPM ≥ 5 axles (Tractor + Larger Trailer) 40 < Vmax ≤ 60 km/h 12,000 kg and R4b trailers, 40 < Vmax ≤ 60 km/h Partial ABS ABS on any Category T1b tractors, MPM ≥ ABS on Category R3b / R4b trailers, 6 (Larger Tractor + Trailer) 11,500 kg, 40 < Vmax ≤ 60 km/h 40 < Vmax ≤ 60 km/h Partial ABS ABS on any Category T1b tractors, MPM ≥ ABS on Category R3b trailers, MPM ≥ 7 axles (Larger Tractor + Larger Trailer) 11,500 kg, 40 < Vmax ≤ 60 km/h 12,000 kg and R4b trailers, 40 < Vmax ≤ 60 km/h Partial ABS ABS on Category R3b / R4b trailers, 8 ABS on any Cat T1b tractor, Vmax >50 km/h (Faster Tractor + Trailer) 40 < Vmax ≤ 60 km/h

Partial ABS ABS on Category R3b / R4b trailers, MPMaxles ≥ 9 ABS on any Cat T1b tractor, Vmax >50 km/h (Faster Tractor + Larger Trailer) 12,000 kg, 40 < Vmax ≤ 60 km/h

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Thus, the options considered removing all requirements for ABS (Option 1) or, alternatively, increasing the requirements to include tractor and trailers, as well as a variety of alternative permutations of partial ABS requirements:  Trailer ABS instead of tractor ABS.  Restricting ABS only to larger, more powerful vehicles likely to be undertaking substantial on-road transport work (see Section 7).

 Restricting ABS only to higher speed vehicles within the 40 < Vmax ≤ 60 km/h range, targeting only higher risk vehicles. The options have considered only a limited range of vehicle categories (T1, R3 and R4). This is because:  Evidence showed that ATVs and SBS vehicles were involved in only a very small fraction of agricultural vehicle collisions. In addition to this, their use in on-road transport was considered to be very low due to inherently low carrying capacity and their mass is more comparable with on-road ‘car like’ quadricycles which despite 100% road use, do not require ABS.  The majority of on-road agricultural transport activities are likely to be undertaken by Category T1 and R3 or R4 vehicle combinations (see Sections 2.3 and 3.3). S2 vehicles performing load-carrying functions will also fall under Category R3 or R4. No T2b vehicles are currently available and transport activities form a small proportion of their normal usage (Nathanson, Scarlett, & Barlow, 2014). T4.3b vehiclesDraft are produced in small numbers and, by definition, are of relatively low mass (MPM ≤ 10,000 kg). However, it should be noted that if the option is to remove the mandatory requirement for ABS on tractors of T1b, it would be removed from all categories of tractor with a maximum design speed of between 40 and 60 km/h.

8.3 Costs of ABS when fitted to a new vehicle Engagement with the agricultural vehicle industry has led to the definition of a range of feasible additional costs that would be expected to result in the following marginal increases in the price of a new vehicle:  Tractor: €3,000 to €5,000.  Small trailer: €1,300 to €1,900 (reflecting likely absence of pneumatic braking system & axle(s) to readily accept wheel speed sensors).  Large Trailer: €500 to €1,000. These are based on a variety of information sources:  Collective industry estimates (e.g. CEMA, CLEPA).  Detailed information from individual manufacturers and tier one suppliers on component and R&D costs.  Published information on the actual existing system price where ABS is already specified as an optional extra. The estimates are, therefore, relatively soundly sourced. However, it is not just important to consider what the price is now but also in the future. A range of factors could influence that going forward:  Optional or standard fit: Where a customer chooses an option because they see value in it, it is a premium, discretionary purchase. Where a feature is standard fit on every vehicle, then there is no premium benefit for the customer and it becomes a commodity. Thus, the price charged for mandatory standard fit items is at the, typically low, margin for the overall vehicle while optional extras are often priced higher, allowing an increased margin. Thus, the change to mandatory

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fit may decrease both the price to the farmer but also any margin made on the feature by the manufacturer.  Designed in from the start: When a feature is added into an existing product, it requires a range of modifications to make it fit and work correctly. When an entirely new model is designed, it is often possible to accommodate the new feature more efficiently at lower cost. Thus, the marginal price of ABS may reduce as brand new models are designed with it from scratch.  Economies from scale: Agricultural ABS is currently sold in very low volumes. Volumes will increase very substantially if made mandatory and this is likely to decrease the price. Thus, the prices above have been included as those for the year 2020. No rigorous evidence on the scale of the above reductions was identified so an arbitrary assumption was made that over the period 2020 to 2030, the price would reduce by between 1% and 4% per year before stabilising at the lower level for the remainder of the evaluation period (2030-2035). Proper consideration of the 'affordability' of systems to farmers would require assessment of the effect of the increase in price on the sales volume of new tractors, effectively the frequency with which they are replaced. Economists use the concept of ‘price elasticity’ as a simple measure of this effect and it is defined as a ratio that says, for example, that a 10% increase in price will result in a 1% fall in sales. This information should be derived empirically in a market that is relevant to the measure being assessed. No information onDraft such elasticities could be readily found in the literature relating to agricultural tractors. (Jorgensen & Persson, 2013) report a low price elasticity in relation to brand choice (that is customers would often stick with a given brand despite price increases relative to competitors) but not in relation to replacement time. A detailed survey to develop new empirical data was beyond the scope of this study. Thus, proper conclusions about affordability cannot be drawn. However, it is possible to state that low voluntary uptake of ABS where it is available as an option suggests that the end-user feels it may cost more than it is worth. However, whether that would be sufficient to affect the likelihood of buying a new vehicle with ABS instead of keeping an old one without ABS is a different question involving additional considerations around reliability, maintenance, capability and new features. As noted, all consideration of the costs in the CBA have been the purchase price for the farmer. In the widest economic sense, this additional cost on the farming industry, could have undesirable effects in terms of reducing profits increasing food prices or decreasing production or competition within farming if it resulted in reduced productivity. However, it will also represent a transfer to other industries. For example, the OEM, the tier 1 supplier and all of the other actors in the supply chain would be expected to make a profit on increased sales of ABS. The work would also increase employment in that industry and those employees would spend their money in other economic areas. Governments would tax the sale price of the vehicle, the corporate profits, individual incomes and the spending of individuals employed in the respective industries. Thus, losses in one area may be offset in other areas. Consideration of these wider economic impacts and the balance between the farming, vehicle manufacture and vehicle supply chain industries has not been considered in this assessment. It is effectively from the point of view of the farming industry only.

8.4 The benefits of ABS The main benefit of ABS is a reduced risk of on-road collisions where instability as a consequence of locked wheel braking was a contributory factor. However, it may also have a range of secondary benefits (see also Section 6.3):  Improved control over brakes, resulting in opportunities for new functions without requiring such a significant increase in hardware on the vehicle, for example: o Hill hold assist.

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o Dynamic balancing of braking loads between tractor and trailer. o Traction control. o Brake Assist. o Roll stability control.  Reduced tyre wear during heavy braking.  Off road collisions o In some circumstances, such as loose gravel standard ABS may worsen brake performance o In other circumstances, such as wet grass, it can improve off-road brake performance o New control strategies have been proposed to minimise or eliminate any dis- benefits and maximise benefits off-road. None of these secondary benefits of ABS have been explicitly monetised in this analysis because of a lack of available data. For example, no data was available quantifying the benefits of additional systems or to document how many off-road collisions were contributed to by braking instability. Two distinct methods of quantifying the benefits were identified, each of which has their own strengths and weaknesses: 1. Post-hocDraft statistical studies of the effectiveness of ABS: These attempt to measure actual in-service performance so are more realistic but can suffer from confounding factors because a wide variety of parameters influence collision risk. They are proof of association not causation and, in this particular case, they are only available where ABS has been fitted to very different types of vehicle (cars, HGVs and motorcycles). 2. Predictive studies: These are based on dividing real world collisions into groups that it is considered the measure can benefit and estimating the effectiveness within that group by reference to experimental results. They avoid confounding factors but also cannot, by definition, account for unforeseen and unintended consequences. It has the advantage of being based on agricultural vehicle collisions but suffers from a lack of detail in that data and low volumes of collisions reducing the ability to detect trends and accurately size the groups. Thus, the cost benefit analysis has estimated the effectiveness of ABS by both methodologies. Within each methodology a range has also been applied to reflect the uncertainty in the results. As such, 4 baseline estimates of effectiveness have been made:  Predictive studies: 25% to 50% reduction in the risk of collisions (any severity) involving skidding or jack-knifing.  Retrospective studies: o Lower effectiveness based on the study of passenger car ABS: ▪ 0% reduction in all fatalities from collisions involving agricultural vehicles. ▪ 3% reduction in serious collisions. ▪ 6% reduction in slight collisions. o Upper effectiveness based on the study of HGV ABS: ▪ 2% reduction in all fatalities from collisions involving agricultural vehicles. ▪ 2.5% reduction in serious collisions. ▪ 3%% reduction in slight collisions.

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Studies of passenger car ABS (Kahane & Dang, 2009) have found that the performance of ABS appears to improve over time, as drivers become more familiar with it. Therefore, the upper estimate based on retrospective studies (but not the lower estimate or either made on a predictive basis) includes an uplift in the effectiveness over the period 2020 to 2030 such that in 2030 to 2035 it is 3.2% of all fatalities, 3.9% of all serious and 4.7% of all slight injuries from collision involving agricultural vehicles. The predictive technique is based on the number of jack-knife collisions. Jack-knife collisions can occur with well-balanced brakes where speeds are high. They can also occur at lower speeds when the brakes on tractor and trailer are not well balanced. The relatively new braking requirements (Regulation (EU) 2015/68) for agricultural vehicles includes measures intended to improve the balance of braking between tractor and trailer, in the form of compatibility corridors. These will act to reduce the chances of jack- knife that occur as a consequence of poor brake balance but not those as a consequence of wheel lock at high speeds. Thus, it can be argued that this measure, which is already implemented but not yet strongly penetrating the market, will take some of the benefit of ABS. The proportion of jack-knife collisions caused by each mechanism is not known so this cannot be split precisely. In deriving an assumption that ABS, which can eliminate jack- knife entirely on a test track, would deliver 255 to 50% of the possible benefit, the fact that the compatibility corridors in the final version of the new braking regulations were considerably wider than originally proposed so as to reduce the technical impact on vehicles, was considered. The fact that trailers can still be approved under very variable national regulation,Draft such that they may still in some cases not comply with compatibility corridors was also considered.

It should be noted that ABS can improve stopping distances in certain circumstances. The requirements of the new braking Regulation (EU) 2015/68 will also improve stopping distances and other aspects of brake performance, such as failures caused by brake fade. These aspects of brake performance are not expected to directly affect the number of jack-knife crashes and the estimated benefit of ABS does not include any reduction in any crashes other than those involving skidding or jack-knife. Thus, the estimate could be considered conservative and avoids much of the possible overlap with the benefits of the new braking regulation. Some options consider application of mandatory ABS to only the tractor unit or only the trailer. (Dodd, Bartlett, & Knight, 2006) showed that ABS on the tractor only could achieve very significant improvements in stability even when the trailer was not fitted with ABS. Thus, it has been estimated that all effectiveness figures should be reduced to 75% of their value where only the tractor is equipped. Similarly, where the trailer only is equipped, it has been estimated that the effectiveness would reduce to 75% of the full combination. However, in this case, it is further reduced by the proportion of skidding or jack-knifing collisions that involved a tractor towing a trailer (72% of fatal, 61% of serious and 52% of slight based on GB statistics). In simple terms some accidents involved a tractor without a trailer skidding and trailer ABS cannot influence such collisions. As a worked example, the lower retrospective effectiveness of ABS applied to trailer only in a slight casualty collision would be 6%*75%*52%=2.3%.

8.5 Forecasting the distribution of sales by vehicle type and how the fleet changes as a consequence Data regarding the sales of vehicles in the EU is required in order to quantify the industry wide cost of fitting ABS for each year of the evaluation period. This needs to be divided into the same categories as defined in the policy options Data, categorised by the same vehicle types, is required about the total number of vehicles registered for road use in the EU, for each year of the evaluation period. This must be combined with the new vehicle sales information and information about the fitment of ABS to those new vehicle sales to estimate the proportion of the tractor fleet

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that will be equipped with ABS in any given year of the evaluation period. This is required to help convert the change in collision risk associated with ABS to the actual number of casualties reduced. That is, the total expected benefit of ABS would only be fully achieved when all agricultural road transport was undertaken by vehicles equipped with ABS. This data does not exist at any level in the EU. CEMA were only able to provide to the project a single point estimate that in 2016 there were 170,000 tractors sold in Europe, of which around 17,000 were capable of in excess of 40 km/h. EuroStat does not provide the required information. The development of estimates has, therefore, necessitated the use of a range of sample sets of data from a small number of individual Member States and national trade bodies combined with assumptions. This does introduce significant elements of uncertainty in the analysis. (Jorgensen & Persson, 2013) reported an EU agricultural tractor market of 150,000 in 2011. Stakeholders suggested that CEMA collected statistics on only 24 of the 28 EU Member States and that for the 24 collected, the total was 125k-135k. It was also noted that CEMA collected statistics on several non-EU European countries, such as Turkey. National data obtained for 6 EU countries (France, Germany, Italy, UK, Spain and the Netherlands) showed a declining trend in overall sales but an increasing trend in the sale of more powerful vehicles. Analysis of samples of data from regional dealerships, farm contractors and two individual tractor manufacturers allowed estimates of the proportion of vehicles capable of Vmax > 40 km/h and due to the small numbers of vehicles capable of Vmax >60 km/h,Draft it was assumed that all of these were capable of 40-60 km/h. Forecasts were undertaken based on both correlation with recent trends and reaching an acceptable end point. These mostly involved logarithmic trend lines. For example, in some cases this was the best fit with past data, but in other cases the best fit was an exponential or polynomial trend which gave implausible (e.g. one category being in excess of 100% of the fleet) results by the time the end of the evaluation period was reached. In the first stage this forecasting was applied to new vehicle sales data. Where possible this was replicated for vehicle stock data. However, where appropriate the values for stock were calculated from an average scrappage rate derived from stock data and adding the new sales generated from the forecast above. In effect, this was a partial ‘churn’ model of the vehicle fleet. For many of the subdivisions of vehicle category, this was based at a detailed level on UK data as the main source of detailed information available. The data was scaled to an EU level using the best data available with respect to the national information for the above mentioned 6 EU countries and the overall fleet sizes estimated by CEMA, (Jorgensen & Persson, 2013) and other stakeholders. This therefore, accounted for the fact that the UK has been a relatively advanced market for high speed tractors in the past, with many other Member States not accepting them at all. Type Approval will now ensure that all Member States must permit high speed tractors to be sold. It has been assumed that by 2035, all of the EU will be adopting them at similar rates to the UK. It should be noted that this technique matches the single point estimate provided by CEMA for 2017. The results for the main vehicle categories of interest are presented in Figure 8.1.

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Figure 8.1: Forecast Volume of EU sales of tractors of different types Draft With respect to fitment of ABS on tractors, it was assumed that a small proportion (1%) of 40-60 km/h tractors would voluntarily be equipped with ABS: Mainly JCB Fastracs but also where traditional tractors such as Fendt and CNH see take up of their optional systems. For Option 1 where no vehicle sees mandatory ABS, it was assumed this optional fitment halves as companies move away from their investments in this area. Some stakeholders have indicated that they would consider this strategy. Where options mandate fitment in 2020, it was assumed that there would be a short ramp up from that value ahead of the deadline with 5% in 2018, 30% in 2019 and 100% compliance in 2020. This resulted in the following estimates of fleet penetration (total registrations) as shown in Figure 8.2 and Figure 8.3.

Figure 8.2: Forecast fleet penetration of ABS-equipped tractors in different policy options

It can be seen that the blue lines representing options where fitting ABS to T1 tractors would be mandatory give the highest fleet penetration, options where there is no

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mandatory requirement (orange line) give the lowest. Between these limits, options involving only those T1 tractors above a mass threshold (grey line) results in a higher market penetration than requiring ABS only for those whose Vmax exceeds 50 km/h (yellow line). Effectively, this means that more tractors are sold with a mass in excess of the threshold than with a speed capability exceeding 50 km/h.

Draft

Figure 8.3: Forecast fleet penetration of ABS-equipped trailers in different policy options

8.6 Developing the business as usual baseline (option 1- remove requirement for ABS) Two target populations are required to match the two different approaches for estimating effectiveness. One is the total number of casualties from collisions involving agricultural vehicles in the EU, divided by casualty severity. This has been sourced directly from the CARE database. The other is the total number of casualties from collisions involving skidding or jack-knifing in the EU, divided by casualty severity. This information is not recorded in CARE. It was, therefore, derived by factoring the EU totals in the CARE database by the proportion of the relevant collision types in GB (11% of fatalities, 9% of serious and 8% of slight). Effectively this assumes that collisions in Great Britain are broadly representative of those in the EU as a whole. Where comparisons were available this was generally found to be true except when considering the ages of vehicle involved. In theory, the proportion of skidding and jack-knife collisions might be expected to be changing significantly as a result of:

 Increasing speed capability of vehicles would be expected to increase risk.  Fewer vehicles carrying more goods (higher mass) per vehicle for the same transport task, potentially on different roads, has the potential to either increase or decrease the frequency of jack-knife collisions.  Improving fundamental brake performance, particularly improved trailer braking and better tractor/trailer balance, at least partly as a consequence of Regulation (EU) 2015/68, would be expected to decrease risk.

It was not possible to separate speed capability or actual speed at the time of collision in the accident data so the different mechanisms could not be analysed separately. Examination of the trends in skidding or jack-knifing, and indeed in relation to speed causes, did not reveal significant changes in the patterns over time. However, the

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numbers involved were low and subject to considerable random scatter pattern. Thus, at this time, no firm conclusion can be drawn on whether increasing speed capability of tractors without ABS presents an increasing risk of jack-knife, or whether the other brake improvements are reducing it. This must be considered an absence of evidence in relation to both possible effects, rather than evidence of an absence of effect. For this reason, the average proportion of skidding/jack-knife collisions was used and remained constant throughout the forecast period. The target populations were forecast for future years. Over the long term, the number of casualties has been reducing strongly but this has slowed and, in many categories, come almost to a stop in recent years. It is thought that the traffic reducing effect of recession and the subsequent increase in the recovery period may be one influence in this but also increases in collisions caused, for example, by distraction due to the use of modern technology such as smartphones while driving/walking etc. Thus, forecasts were generally based on a continued slow decrease levelling off as the effect of policies already implemented saturates the market (Figure 8.4).

Draft

Figure 8.4: Actual and forecast number of slightly injured casualties from collisions involving agricultural tractors in the EU Source: TRL analysis of CARE data (European Commission, 2017)

However, with respect to fatalities from agricultural vehicles there was evidence to suggest a slightly different trend. Firstly, there was the theoretical evidence that suggests that increasing use of high speed tractors across Europe will generally increase collision severity across different types of collision. This combines with the fact that both in Great Britain and the EU a change in the relationship between fatalities and lower injury severities could be seen, suggesting an increase in the fatality rate per 100,000 vehicles and that agricultural vehicle fatalities represent a growing proportion of all road fatalities. As such, it was forecast that for fatalities from all types of collisions involving agricultural vehicles (not just those where ABS is a relevant consideration), the slow decline would in the future be replaced by a slow increase in the number, in the absence of new policies to control these risks (see Figure 8.5).

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Figure 8.5: Actual and forecast number of fatalities from collisions involving agricultural tractors in the EU DraftSource: TRL analysis of CARE data (European Commission, 2017)

As a baseline, it has been assumed that around 1% of new vehicle sales in the relevant categories as a consequence of standard fit across the range from JCB and small numbers of optional take up from manufacturers such as Fendt and CNH. In scenario 1, this has been reduced to around 0.5% in future years, reflecting the expression of some tractor OEMs that stated that they would consider walking away from ABS given a choice and the general lack of incentive for further investment that may be signalled by such a move. Within each scenario, the fitment of ABS in each year as a percentage is multiplied by the new vehicle sales figure for each year to produce a number of new vehicles equipped with ABS. The partial vehicle churn model is used to sum these new sales, minus scrappage, into estimates of the number of such vehicles in the fleet. For the sake of simplicity it was assumed that the number in the fleet in 2005 was zero. This is not strictly true because JCB had been producing vehicles with ABS for a few years before this but the overall number at that time would represent a negligible proportion of the EU parc.

8.7 Estimating and valuing casualty reductions

The estimation of casualty reduction as a consequence of ABS in each scenario is a simple calculation: 푁푢푚푏푒푟 표푓 푏푎푠푒푙푖푛푒 푐푎푠푢푎푙푡푖푒푠 ∗ 푝푒푟푐푒푛푡 푒푓푓푒푐푡푖푣푒푛푒푠푠 ∗ 푝푟표푝표푟푡푖표푛 표푓 푓푙푒푒푡 푒푞푢푖푝푝푒푑 These terms have already been defined (see preceding sections) and the first two terms are straightforward. However, the linear use of the proportion of the fleet equipped can be controversial. In normal road vehicle analyses, the assumption that if 10% of the fleet is equipped with the measure then 10% of the total expected benefit will be achieved is usually accepted. However, it is often debated because it may be argued, for example, that newer passenger cars tend to travel longer average distances than older cars, therefore they are more likely to become involved in a collision just due to exposure and so the benefits of the new measure will accrue faster than implied by the linear rate. However, the counter argument is that they can also be shown to travel more on motorways which are safer roads and by the fact that in general people get wealthier as

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they get older, they tend to be bought by an older, safer demographic of driver. Thus, the influence of the measure will be felt more slowly than implied by the linear assumption. When considering agricultural vehicles, the situation is different because they are purchased as a capital investment intended purely to bring a financial return. There is a strong argument that newer vehicles will perform a disproportionate volume of the road transport task compared with older vehicles. There is also an unusually large ‘historic’ fleet of very old tractors. For example, in 2016 in the UK, 40% of vehicles registered were in excess of 25 years old. These are relatively unlikely to be used intensively in frontline roles involving extensive road use. Thus, using the percent of vehicles equipped in a linear relationship to collision risk would appear to under-estimate the risk. UK collision data would support this theory, showing that 60% of collisions involving tractors involved one that was less than 5 years old. Based on this data, a linear relationship between percentage of total fleet equipped and casualty reduction would grossly under estimate the effect. However, (CEMA, 2015) argue not that newer vehicles are not more involved in transport tasks but that they are orders of magnitude safer than older vehicles such that it is older vehicles that are involved in most collisions, with 69% of fatal collisions involving a vehicle in excess of 12 years old. This position is also broadly supported by data for some other EU Member States with the relevant data available in CARE. Based on this data, a linear relationship between fitment rate and casualty reduction would slightly over- estimate the effect. The reason forDraft this stark difference in the distribution of collision risk by age of tractor between Great Britain and some other EU countries is not known. In the absence of additional data, a linear relationship has been retained. The prevention of a casualty has been monetised at the following rates:

 Fatal: €1,564,503  Serious: €231,278  Slight: €17,753 These values were calculated by (Hynd, et al., 2015), and adopted by (Seidl, et al., 2017)

8.8 Results of the CBA The overall results of the cost benefit analysis are summarised in Table 8.2. As a reminder, the effect of the options presented in Table 8.2 are calculated relative to the ‘do nothing’ option, that is, Option 0 where ABS becomes mandatory on tractors as it is currently written into the Regulation (EU) 2015/68. The costs of fitting ABS and the total cost of casualties are summed for ‘do nothing’ (Option 0) and for each ‘do something’ scenario (Options 1-9). The costs of fitting ABS and the costs of casualties associated with the ‘do nothing’ scenario are subtracted from each ‘do something’ scenario. Where total costs of fitting ABS and casualties are less in a ‘do something’ scenario than they are in the ‘do nothing’ scenario then the relative result is a negative number, a reduction in cost compared to mandating ABS on tractors. An overall reduction in cost is considered beneficial. Summing those beneficial cost reductions over the years evaluated gives a total benefit of the policy. However, the values are discounted by 3.5% each year to reflect the economic norm that considers future money is worth less than the same amount of money now. The revised total is normally referred to as the net present value. The benefit to cost ratio is calculated by dividing the ‘benefit’ of reduced ABS fitment costs by the ‘cost’ of increased casualty cost.

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The policy option with the largest net monetary gains will not necessarily be the one with the best benefit to cost ratio. If a policy options has very large benefits (e.g. €11 billion) and very large costs (e.g. €10 billion) it can have a very high net monetary gain (€1 billion) but the benefit to cost ratio could be fairly low (e.g. 1.1). A different option with lower benefits and cost (for example €2000 benefits and €1000 costs) would have only a small net monetary gain (€1000) but a much better benefit to cost ratio (2). Which measure, or combination of the two measures, an organisation should use to determine the ‘best’ option depends on the objectives of the organisation generally, and the policy under assessment specifically and their interpretation of the risk. Selection of which policy is the ‘best’ to implement in this case will, therefore, be a matter for the European Commission and any impact assessment they choose to undertake. Such assessments should consider both the monetary affects should be balanced alongside the non-monetised risks highlighted. The sums in the table below represent the total for the evaluation period to 2035. Either a reduction in the cost of fitting ABS or a reduction in the number of casualties, or the monetary value associated with those casualties, would be considered beneficial and is highlighted in green. Increases in cost or casualties are highlighted in red.

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Table 8.2: Summary results from the cost benefit analysis

Benefit to Cost Change in Change in serious Change in Option Option description Net Present Value (NPV) of change ratio (BCR) fatalities casualties slight casualties Upper Lower Upper Lower Upper Lower Upper Lower Upper Lower 1 No ABS -€ 3,037,294,695 -€ 1,375,623,885 308 20 46 - 125 54 349 169 Partial ABS 2 -€ 2,795,622,155 -€ 1,330,377,956 384 29 32 - 93 40 274 133 (Trailer only) Partial ABS 3 -€ 2,804,117,775 -€ 1,334,937,386 383 29 33 - 94 40 275 134 (Larger Trailer only) Full ABS 4 € 72,020,149 € 207,194,931 0.23 0.01 -14 - -34 -15 -81 -39 (Tractor + Trailer) Draft Partial ABS 5 € 67,491,099 € 198,703,711 0.23 0.01 -14 - -33 -14 -80 -39 (Tractor + Larger Trailer) Partial ABS 6 -€ 1,120,109,372 -€ 548,255,120 608 54 7 - 24 10 80 39 (Larger Tractor + Trailer) Partial ABS 7 -€ 1,128,603,424 -€ 552,803,618 596 52 7 - 24 11 82 40 (Larger Tractor + Larger Trailer) Partial ABS 8 -€ 2,075,868,849 -€ 999,154,174 407 31 22 - 65 28 195 95 (Faster Tractor + Trailer) Partial ABS 9 -€ 2,084,465,815 -€ 1,003,774,472 404 31 22 - 66 28 197 96 (Faster Tractor + Larger Trailer)

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Based on the net (benefits minus costs) present value figures, selecting policy option 1 and removing the requirement to fit ABS to agricultural vehicles would result in the largest monetary gain. The net present value associated with the option includes the benefit of reduced costs of fitting and buying ABS and the cost associated with a predicted increase in the number of fatalities from collisions involving agricultural vehicles. The prediction is that up to 46 more fatalities would be expected (across the EU up to 2035) under policy option 1 compared with doing nothing (policy option 0). The lack of collision speed information and the lack of data around the market penetration of 40-60km/h tractors contribute to substantial uncertainty in the analysis. This results in a wide range of estimated effects. However, it can be seen that even at the extremes of the possible ranges, the overall effect of this option is always beneficial and the benefit to cost ratios are always substantially in excess of 1.

Mandating ABS on all 40 < Vmax ≤ 60 km/h Category T1b, R3b and R4b vehicles or mandating ABS on Category T1b and Categories R3b and R4b vehicles of MPMaxles ≥ 12 tonnes (Options 4 & 5), are the only two options with a BCR of less than 1 where the costs of increased fitment of ABS outweigh the benefits of predicted casualty reductions. In this case, the best BCR is achieved by mandating the fitment of ABS on T1b tractors of MPM ≥ 11.5 tonnes and either all R3b and R4b trailers or just those of MPMaxles ≥ 12 tonnes (Options 6 and 7). Such options would lessen the overall net gain to between €0.55 billion and €1.1 billion. However, the improved BCR comes from the fact that the associated increase in casualties is lessened by proportionally more than the cost of fitting the systemsDraft is increased. Requiring ABS only on T1b tractors with a Vmax capability in excess of 50 km/h and on trailers of R3b and R4b, or only those with a MPMaxles>12 tonnes (Options 8 and 9) falls between the best monetary gain and best BCR on both measures. However, it would complicate the legislation by introducing a new speed threshold not used in any other part of the type-approval process. The analysis above considers only the parameters that could be identified and monetised. For each of the options analysed there is also a range of non-monetised considerations that should be weighed alongside the numerical analysis.

8.8.1 Non-monetised considerations related to all options The results for each option are obtained by measuring the difference between the costs and the casualty prevention values of the selected option and the equivalent values from Scenario 0, the ‘do nothing’ option. These results are shown in Table 8.3. The range of uncertainty, a consequence of data limitations described previously, is already significant but several important factors may still have further influence:  The forecast of future casualty trends assumes only a very small effect of increasing tractor speed on collision severity, with no effect on collision frequency. If this effect proves larger or smaller in practice, then it will have a substantial effect on the calculated benefits of ABS because a small change in absolute numbers can be a large proportional change.  The baseline estimates of the proportion of the agricultural vehicle fleet that fall into each category is not well defined by existing data and has required considerable estimation based on extensive market knowledge. Variations that apply equally to sales and total fleet will affect absolute numbers but not the direction of the result. Variations that affect sales more than the vehicle parc or vice versa will affect benefit to cost ratios and, if sufficiently large, the direction of result.

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Table 8.3: Detailed Annual Results for policy option 1 – expressed as changes in costs and casualty prevention values relative to those predicted for the ‘do nothing’ option of allowing ABS to become mandatory

Policy Option 1 - Remove requirement for ABS

Year Costs (negative= benefit) Casualty value (negative = benefit) Net effects (negative beneficial, positive disbeneficial)

Upper Lower Upper Lower Upper-Lower Lower-upper Upper-Upper Lower-lower

2016 € - € - € - € - € - € - € - € -

2017 € - € - € - € - € - € - € - € -

2018 -€ 4,567,270.37 -€ 1,526,127.70 € 16,309.18 € 2,193.26 -€ 4,565,077 -€ 1,509,819 -€ 4,550,961 -€ 1,523,934

2019 -€ 36,949,239.68 -€ 16,998,650.34 € 144,592.55 € 19,468.82 -€ 36,929,771 -€ 16,854,058 -€ 36,804,647 -€ 16,979,182

2020 -€ 138,847,218.02 -€ 71,510,363.13 € 612,997.95 € 82,566.70 -€ 138,764,651 -€ 70,897,365 -€ 138,234,220 -€ 71,427,796 2021 -€ 149,370,322.70 -€ 76,307,829.49 Draft€ 1,084,391.69 € 151,686.23 -€ 149,218,636 -€ 75,223,438 -€ 148,285,931 -€ 76,156,143 2022 -€ 158,607,063.01 -€ 80,083,393.20 € 1,556,984.32 € 226,016.83 -€ 158,381,046 -€ 78,526,409 -€ 157,050,079 -€ 79,857,376

2023 -€ 166,943,820.22 -€ 83,012,133.42 € 2,030,665.23 € 305,666.21 -€ 166,638,154 -€ 80,981,468 -€ 164,913,155 -€ 82,706,467

2024 -€ 174,419,989.91 -€ 85,183,143.13 € 2,505,658.87 € 386,718.67 -€ 174,033,271 -€ 82,677,484 -€ 171,914,331 -€ 84,796,424

2025 -€ 181,076,563.80 -€ 86,679,368.72 € 2,982,473.72 € 457,918.14 -€ 180,618,646 -€ 83,696,895 -€ 178,094,090 -€ 86,221,451

2026 -€ 186,955,270.69 -€ 87,577,563.34 € 3,461,851.55 € 528,124.14 -€ 186,427,147 -€ 84,115,712 -€ 183,493,419 -€ 87,049,439

2027 -€ 192,097,937.58 -€ 87,948,390.31 € 3,944,717.82 € 597,214.33 -€ 191,500,723 -€ 84,003,672 -€ 188,153,220 -€ 87,351,176

2028 -€ 196,546,014.63 -€ 87,899,071.73 € 4,432,045.36 € 665,076.14 -€ 195,880,938 -€ 83,467,026 -€ 192,113,969 -€ 87,233,996

2029 -€ 203,084,609.83 -€ 88,682,361.64 € 4,934,888.54 € 733,100.63 -€ 202,351,509 -€ 83,747,473 -€ 198,149,721 -€ 87,949,261

2030 -€ 206,163,418.17 -€ 87,775,113.79 € 5,443,717.43 € 799,595.03 -€ 205,363,823 -€ 82,331,396 -€ 200,719,701 -€ 86,975,519

2031 -€ 208,206,865.91 -€ 89,036,944.21 € 5,950,120.88 € 863,105.41 -€ 207,343,760 -€ 83,086,823 -€ 202,256,745 -€ 88,173,839

2032 -€ 209,919,060.35 -€ 90,128,514.05 € 6,455,950.52 € 923,733.11 -€ 208,995,327 -€ 83,672,564 -€ 203,463,110 -€ 89,204,781

2033 -€ 208,888,509.08 -€ 89,987,695.19 € 6,953,570.88 € 980,254.30 -€ 207,908,255 -€ 83,034,124 -€ 201,934,938 -€ 89,007,441

2034 -€ 205,338,255.72 -€ 88,714,277.46 € 7,435,920.37 € 1,031,620.84 -€ 204,306,635 -€ 81,278,357 -€ 197,902,335 -€ 87,682,657

2035 -€ 199,482,262.34 -€ 86,403,947.14 € 7,896,378.31 € 1,076,944.16 -€ 198,405,318 -€ 78,507,569 -€ 191,585,884 -€ 85,327,003

Total -€ 3,027,463,692 -€ 1,385,454,888 € 67,843,235 € 9,831,003 -€ 3,037,294,695 -€ 1,453,298,123 -€ 2,959,620,457 -€ 1,375,623,885

BCR 308.0 20.4 44.6 140.9

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 The costs of ABS estimated for agricultural vehicles are high, at least an order of magnitude higher than for other vehicle types, and potentially two orders of magnitude compared with cars. These are consistent with prices charged by those currently offering systems as options. Typically, prices are much lower when a system is mandatory fitment on all vehicles, such that it has no discretionary value to the customer. Fitment will be mandatory on agricultural vehicles capable of more than 60 km/h. The number of these is low but information from one manufacturer does suggest an increase in cost at the low end of the range.  The benefit of ABS is calculated as being directly proportional to the proportion of the total fleet equipped. The agricultural vehicle fleet contains an unusually high number of extremely old vehicles, such that the proportion of the total fleet replaced with new vehicles each year is relatively small. However, evidence suggests that the younger vehicles do the vast majority of the hard work of farming. If the benefit of ABS was linked to the proportion of this ‘hard working’ fleet that was equipped then the benefit predicted would increase substantially.  In the automotive market, ABS was a platform from which may other additional safety and convenience functions were evolved, including traction control, brake assist, stability control etc. Given the higher costs of development relative to sales in the agricultural vehicle market, there is a risk that removing the strong market signal that mandatory ABS will provide will limit abilities to replicate the success of the automotive market in other areas of agricultural safety development (e.g. rollover prevention). ABS also hasDraft the potential to influence the frequency or severity of off-road collisions, positively or negatively depending on the surface conditions and ABS specification. These collisions could not be quantified within the scope of this work.  None of the analyses undertaken in this cost benefit study account for the economic value that the farming industry gain from an increase in the number of vehicles with a speed capability of between 40 and 60 km/h or the amount that they are willing to pay to gain that capability.

8.8.2 Non-monetised considerations related to options that fully or partially remove the requirement for Tractor ABS (Options 1, 2, 3, 6, 7, 8, 9) Many companies within the industry, particularly tier 1 suppliers such as WABCO, have invested considerable sums of money in developing ABS solutions that will work in the agricultural vehicle market, particularly in relation to hydraulic systems. If this option is selected, stakeholder feedback suggests that the voluntary take up of ABS in the market will remain very low and may even decrease compared with the preceding period. Thus, those sums invested to date by the industry will not be recovered from sales.

8.8.3 Non-monetised considerations related to options involving mandating ABS on trailers (Options 2, 3, 4, 5, 6, 7, 8, 9) Little difference was found between fitting trailer ABS to all R3b/R4b trailers and fitting it to just those of MPMaxles ≥ 12 tonnes. This is because it was considered that very few trailers of less than 12 tonnes were used, or intended for use, in higher speed towing. However, it should be noted that the smaller trailers would typically use hydraulic braking systems for which ABS is not readily available, thus forcing them to upgrade to commercial standard air braked axles at additional unit cost. Such an upgrade may or may not have other effects.

8.8.4 Non-monetised considerations relating to options involving mandatory ABS on T1b tractors that were capable of more than 50 km/h only. At present, most tractors capable of between 40 and 60 km/h are actually capable of a maximum design speed of 50 km/h. A significant proportion of those capable of higher

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speeds that currently exist will already have ABS (e.g. JCB Fastrac). However, as type- approval forces all EU countries to accept the sale of high speed tractors (though it does not force states to allow them to be used at higher speeds) it is likely that the proportion of vehicles capable of in excess of 50 km/h will grow. In physical testing the risk of, for example, jack-knife was found even on a balanced combination to increase almost exponentially from 40 to 60 km/h. Thus, the collision risk that can be mitigated by ABS at 50 to 60 km/h is likely to be disproportionately larger than the risk that can be mitigated at 40-50 km/h. It was not possible to account for this within the model, which assumes the same risk at all speeds between 40 and 50 km/h. Properly accounting for this behaviour would mean the model would see greater benefits of ABS without changing the costs. Thus, this option is, in reality, likely to be slightly more beneficial than it appears in the monetised results.

8.8.5 Sensitivity to changes in the inputs Despite the many uncertainties acknowledged within the model and the wide estimate range resulting, the overall results remain very clear cut. None of the options have a benefit to cost ratio where the range of results, reflecting the uncertainty, spans 1 (where costs = benefits). In most cases even the closest extreme is many times greater than (or smaller than) one. Thus, small changes in inputs are extremely unlikely to influence the overall result and only a limited sensitivity analysis has been undertaken considering the registration data, the cost of ABS and how the number of skidding and jack-knife collisionsDraft might change over time. Changes to the estimates made in registration data can have a substantial effect in terms of the absolute net present values of the options and the casualty numbers. These can change values by a factor of two. However, most changes affect both costs and benefits in similar proportions such that it does not influence relative differences between costs and benefits. Changes that have a different effect on new vehicle sales compared with the total population of vehicles equipped with ABS can affect costs and benefits differently. However, the magnitude of those differences is generally smaller because new vehicle sales directly influence the vehicle population both with and without ABS. Changes to consider the effect of ABS in proportion to how many of the ‘hard working’ fleet of tractors and trailers on the road (assuming a lot of very old tractors (e.g. 25 years or older) do very little work on the road) can vary the casualty effects by almost a factor of 2. However, this remains only a small value relative to the cost (< €100 million against €1-3 billion). The effect of assuming a doubling of the proportion of casualties from agricultural vehicles where instability was involved is of a similar magnitude. Thus, it can be concluded that the cost of the ABS itself is the dominant factor in the result. Adjusting the cost shows that, depending on scenario and other settings, the ‘lower’ case results would suggest an uncertain case (range of BCRs spanning 1) at an ABS cost of the order of €150 to €250 per vehicle. In short, the model would only start to suggest mandatory ABS on tractors might be cost-beneficial at costs of less than around €250 per vehicle.

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9 Analysis and discussion Based on the information presented in the preceding Sections, the following statements summarise the key findings and resulting views that will inform the final conclusions from the investigation, as presented in Section 10.  There is clear evidence that the changing nature of agricultural businesses and farming practices across the EU is increasing the exposure of agricultural vehicles to the risk of road collisions. Business rationalisation and the consequent creation of larger farm units are resulting in the sale and use of fewer but larger (higher- powered) farm tractors. These vehicles are used by a smaller workforce to undertake operations over greater geographic areas (see Section 3.1).  Evidence suggests that tractors in the 150 – 300 hp (112 – 224 kW) power range may spend up to 50% of their operating time engaged either in material transport or general travelling on-road. To maximise operational efficiency during such activities, faster (V max > 40 km/h) tractors are increasingly being used (where national legislation permits), towing heavier loads in order both to utilise available engine power and to match crop harvesting machinery output (see Section 3.3).  Most of these faster tractors have a maximum design speed in the range 40 to 60 km/h. A small number of vehicles, dominated by one manufacturer, have a maximum speed capability in excess of 60 km/h and are already required by nationalDraft regulations (see Section 3.4) or EU type-approval, to be fitted with ABS.  In the past agricultural tractors have, by virtue of their number and usage, represented only a very small proportion of vehicles involved in road collisions. However, the rate at which they occur per registered vehicle is considerably higher than might be expected compared with other vehicle types and the fact that they spend significant amounts of time (≥ 50%) operating off-road. When they do become involved in collisions, they are much more likely than average to prove fatal (see Section 4).

 Vmax > 40 km/h agricultural tractors have been widely available from global manufacturers since 2003-06 and, in certain cases, during the preceding decade. At present only a limited number of EU Member States permit the sale and/or use of such vehicles, but from January 2018 it will no longer be possible to prohibit such sales. Member States may still choose to limit the speed at which they can be used, but responsibility for complying with those limits will rest with the user (see Section 3.4). Evidence suggests that, unless severe penalties are imposed, tractors and associated towed vehicles will be driven at the maximum speed achievable: indeed, it is believed that, in certain circumstances, the smaller difference in speed compared with other traffic can even reduce the frustration and consequent risk-taking of other road users.  Nonetheless, the body of generalised evidence concerning the effect of speed on collisions clearly highlights a risk that the increasing market penetration of high speed agricultural tractors could result in an increase in the frequency and/or severity of road collisions. This is complicated by the effect of reducing the spread of speeds around the average road speed and different patterns of usage of different road types compared with other vehicles (see Section 4). These factors may partially or even fully-offset the underlying increase in risk.  A large body of engineering evidence is available to show that the risk of specific types of crashes, such as loss of control and jack-knife, increases with speed (see Section 5.2).  At present, there is little statistical evidence that these risks have so far caused a significant change in the number or type of collisions involving agricultural vehicles. This is despite an analysis suggesting that, taking the UK market as an

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example, tractors with high speed (Vmax > 40 km/h) capability might represent around 16% of the whole tractor fleet and 32% of the modern fleet (less than 20 years old). There is some evidence to suggest that the number of fatalities is reducing by less than expected, such that the rate per registered vehicle is increasing and fatal agricultural vehicle collisions are becoming a larger proportion of all road fatalities. This would be consistent with general evidence about the influence of speed. However, the data available on agricultural vehicle collisions is extremely limited and reliance on individual Member State data means that sample sizes are small such that, when broken down to specific collision types such as jack-knife, random variation plays a significant role. Thus, at this stage this should be considered an absence of evidence of any of the expected effects, NOT evidence of absence of those effects. Improving the ability to monitor agricultural vehicle road safety performance at the EU level would allow these risks to be much better monitored over time (see Section 4).  There is very clear engineering evidence that ABS is very effective at mitigating the risk of loss of control, jack-knife and trailer swing collisions. There is strong statistical evidence of ABS working to reduce the frequency of this type of collisions when fitted to Heavy Goods Vehicles. However, there is also strong statistical evidence to suggest that the risk of other collision types can increase when HGVs are fitted with ABS, such that the net benefits are smaller than expected. With passenger cars, this effect meant that the increases in risk ins come collisions came very close to fully offsetting the reductions in other collisions such that the net effect on fatalities was almost zero, though there were still benefitsDraft in lower severity collisions (see Section 5.2)  There is also strong evidence that, in other road vehicles, the inclusion of ABS has acted as a development platform for a wide range of other advanced control systems operating through the braking system (see Section 5.2). In particular, the extension of ABS brake control technology to electronic stability control (ESC) systems in passenger cars has had a transformational effect, showing casualty reduction effects second only to those of the seat belt.  There is clear evidence that ABS systems will be technically feasible and available for nearly all relevant agricultural vehicle types (Categories T, R3, R4 & S2). However, the ease and economic feasibility of their installation is currently dependent upon the brake application method / medium used on the vehicle and the physical space available. Systems based on dedicated adaptations of pneumatic truck / truck-trailer systems are already mature in the market and have been utilised commercially on agricultural tractors and trailers. Hydraulic (mineral oil) ABS systems for agricultural tractors are mainly in late-stage prototype form and are expected to be in series production by 2019. Current ABS product development and market availability schedules indicate there is no requirement for (nor any likely market benefit likely to result from) delaying the implementation date for mandatory ABS on 40 < Vmax ≤ 60 km/h tractors beyond the proposed 2020 / 2021 dates.  ABS systems are currently not available for trailers / towed equipment fitted with hydraulically-actuated braking systems and, given limited market demand and possible high development costs, these may not be brought to the market. Consequently ABS installation would require the conversion of such (typically lower-mass, less expensive) trailers / towed equipment to pneumatic braking systems. Perhaps fortunately, most trailers / towed equipment intended for V > 40 km/h use tend to feature pneumatic braking systems. Therefore, regarding technical / engineering criteria, in the majority of instances, there is every justification to fit ABS technology to agricultural vehicles, particularly those of larger mass and/or higher speed capability (see Sections 5.1 and 6).  Thus, there is strong evidence that the collision problem involving agricultural vehicles is a small but possibly growing one, where the risk of fatality per unit of

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exposure is much greater than average. There is a risk that this problem might increase further in the future as higher speed capability further penetrates the market. There is evidence to demonstrate that ABS will have a strong positive effect on specific types of collision directly related to speed and that it will have a small net positive effect on crashes overall. It is clear that it is applicable and technically feasible on most relevant agricultural vehicle.  However, the evidence identified suggests that the cost to farmers of purchasing ABS on their new vehicle is one or two orders of magnitude greater than it is for a consumer purchasing a car. It is, therefore, an expensive countermeasure when applied to agricultural vehicles. As such, the evidence suggests that the reduction in cost associated with removing the requirement for ABS will outweigh the dis- benefits of failing to achieve the anticipated casualty reduction associated with ABS (see Section 8).  Several options are available for the partial implementation of mandatory ABS in the 40 < Vmax ≤ 60 km/h sector. For example, limiting mandatory ABS to tractors capable of Vmax > 50 km/h and large trailers designed for V > 40 km/h operation, will achieve better benefit to cost ratios than simply removing the requirement for ABS. However, overall, these will still have substantially higher net costs than simply removing the requirement.  The monetised benefits must be weighed against the non-monetised risks highlighted, including but not limited to losses in the agricultural vehicle component supply chain, the potential to reduce incentives for future investment in newDraft agricultural vehicle safety technology, particularly those that may use more sophisticated brake control as part of their function, the incidence of off- road collisions and the uncertainty in the future influence of increasing on-road speeds and travel distances in agricultural operations (see Section 8).  Further action to examine the functioning of the market would be required to fully understand how, in the future, the costs of transferring important safety technologies to the agricultural vehicle sector could be minimised. Low production volume is one fundamental factor, but the EU sales volume of agricultural tractors in 2016 was around 130,000. Over the same period, the sales volume of HGVs (trucks) in excess of 3.5 tonnes in the EU-15 was only 210,000 units. Given that the 13 Member States missing from the HGV data are typically the smaller markets, it is likely that the HGV market is less than double the size of the agricultural tractor market. In the case of HGVs, ABS has worked successfully for many years and HGVs have in some way been the pioneers in more sophisticated safety technology such as automated emergency braking. However, the diversity of agricultural tractor size and build specifications undoubtedly presents additional challenges to the introduction of any new technology and this instance is no exception. Understanding the detailed reasons for these higher costs and taking measures where possible to reduce the differential, may prove critical to the success of future safety measures.

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10 Conclusions This investigation was undertaken to assess the current and future state-of-play in the development of technology to allow ABS to be installed on agricultural and forestry vehicles of 40 < Vmax ≤ 60 km/h. To ensure a comprehensive evaluation of the issue, ABS technology was assessed in terms of technical availability, applicability to agricultural and forestry vehicles and the likely costs and benefits of system implementation. In terms of these three criteria, the conclusions of the investigation may be summarised as:

 Technical Availability of ABS: In the majority of instances, systems are readily available for relevant agricultural vehicles.

 Applicability of ABS: Systems are applicable for use on relevant agricultural vehicles deemed likely to undertake agricultural transport operations on-road.

 Cost Benefit Analysis: The likely costs of ABS implementation are high and are unlikely to be outweighed by monetised savings resulting from reduction in casualty Draftnumbers during the 15 year evaluation period. The findings of the investigation are as follows:

 Agricultural vehicle use: Changes in EU agriculture have resulted in the use of fewer, larger (higher-powered) tractors which generally travel over greater geographic areas to perform agricultural operations. Consequently greater on-road distances are travelled, both during material transport and general travel activities.  Agricultural vehicle max speed capability has increased demonstrably. Vmax > 40 km/h tractors have been widely available for ~ 15 years and, where their use is permitted, have proven very popular in the marketplace. Where national legislation permits, they are increasingly used to tow heavier loads in order both to utilise available engine power and to match crop harvesting machinery output. It is likely that their market penetration will increase post-January 2018, following final implementation of EU type-approval legislation.  Accidents involving agricultural vehicles form only a small proportion of the EU total. However, collisions involving agricultural vehicles are around 3 times more likely to be fatal than the average for all collision types. Fatalities occur at a higher rate per registered vehicle than for other vehicle types, despite the limited road usage. Also, the number of fatalities from such collisions appears to be reducing more slowly than other vehicle types, such that they represent an increasing proportion of all fatalities. As higher speed tractors are likely to represent an increasing proportion of the EU fleet in the future, there is a clear risk of an increase in both collision frequency and severity, though the reduction in the speed differential with other road vehicles may counter this. The evidence to-date is very limited but is consistent with an increase in collision severity but not frequency.  Technical availability of ABS: ABS is technically feasible and available for nearly all relevant agricultural vehicle types (Categories Tb, R3b, R4b & S2b). However, the ease and economic feasibility of their installation is currently dependent upon the brake application method / medium used on the vehicle and the physical space available to accommodate system components. Mature pneumatically-based ABS technology is readily-available for use on agricultural tractors (T1b) and also on agricultural trailers/towed equipment (R3b, R4b and S2b). Such ABS systems are already in commercial use on a limited number of T1 tractor models, whilst

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hydraulic (mineral oil) ABS systems are at advanced stages of product development. Commercially-available hydraulic (brake fluid)-based light / medium truck systems are, based on our discussions with industry, understood to be suitable for installation on Category T4.3b vehicles. ABS systems for other tractor categories are either at a proof-of-concept stage or in development (e.g. a commercial hydraulic system for ATVs is expected to be marketed in the very near future). Whilst ABS is readily-available for trailers / towed equipment fitted with pneumatic braking systems, it is not currently available for such vehicles which employ hydraulically-actuated braking systems and may not be brought to the market in the foreseeable future. Such (typically lower-mass, less expensive) trailers / towed equipment would therefore require conversion to pneumatic braking systems to permit ABS installation. However, most trailers / towed equipment intended for V > 40 km/h use tends to feature pneumatic braking systems.  Practical availability and applicability: Vehicle braking system actuation method and/or medium is significant in determining the complexity and associated cost of ABS installation on agricultural vehicles, particularly as the majority of tractors employ hydraulic (mineral oil) brake actuation systems. The diverse nature of tractor design may well require ABS installation to be approached on a model- range by model-range basis. The space available for installation of some current ABS system components may also present a challenge. ABS implementation also requires installation of wheel speed sensors, but this appears to be a surmountable engineeringDraft challenge. For larger (pneumatically-braked) agricultural trailers and interchangeable towed equipment, ABS systems may be installed without difficulty. Smaller vehicle applications are likely to be more costly. ABS technology is currently not available for hydraulically-braked trailers. Valid concerns regarding ABS behaviour during off-road braking have been addressed by the provision of manual or automatic system disablement and/or alternative (slower speed) operating characteristics.  Economic availability: The likely system diversity for ABS implementation on agricultural tractors will potentially increase system installation and development costs, thereby increasing cost to the vehicle user. For reasons of commercial confidentiality it has only been possible for this investigation to estimate potential overall system costs. ABS suppliers have commented that, depending upon production volumes, tractor system costs to OEMs may be in the region ~€1000 – 1300, to which installation and vehicle-based development costs must be added. Where offered as optional equipment, tractor manufacturers currently retail ABS at ~€4000–5000. For agricultural trailers and interchangeable towed equipment, mature pneumatic ABS systems are readily available at reasonable cost (~€500 OEM cost).  Cost benefit analysis: Removing the requirement to fit ABS to agricultural vehicles would result in the largest monetary gain (from between €1.3 billion - 3.0 billion). This represents the cumulative savings in the cost of buying ABS minus the casualty prevention value associated with the additional casualties that would be expected to occur as a direct consequence. There is substantial uncertainty in the analysis which results in a wide range of estimated effects. Benefit to cost ratios (BCRs) are calculated by dividing the savings in the cost of buying ABS by the prevention values associated with the increase in casualties. Even at the extremes of the possible ranges, the BCRs are always substantially in excess of 1.

Mandating ABS on all 40 < Vmax ≤ 60 km/h Category T1b, R3b and R4b vehicles or mandating ABS on Category T1b and Categories R3b and R4b vehicles of

MPMaxles ≥ 12 tonnes, are the only two options with a BCR of less than 1. The option with the largest monetary gain (benefits minus costs) can have a relatively low benefit to cost ratio, where both benefits and costs are large. Conversely where benefits and costs are small, high benefit to cost ratios can be

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achieved while total monetary gains remain small. Which measure, or combination of the two measures, represents the ‘best’ option depends on the objectives of those setting the policy and their interpretation of the risk. Selection of which policy is the best to implement will, therefore, be a matter for the European Commission and any impact assessment they choose to undertake and the monetary effects should be balanced alongside the non-monetised risks highlighted. In this case, the best BCR is achieved by mandating the fitment of ABS on T1b tractors of MPM ≥11.5 tonnes and either all R3b and R4b trailers or just those of MPMaxles ≥ 12tonnes. Such options would lessen the overall net gain to between €0.55 billion and 1.1 billion. However, the improved BCR comes from the fact that the associated increase in casualties is lessened by proportionally more than the cost of fitting the systems is increased.

Requiring ABS only on T1b tractors with a Vmax capability in excess of 50 km/h and on trailers of R3b and R4b (or only those of MPMaxles ≥ 12 tonnes) falls between the best monetary gain and best BCR on both measures. However, it would complicate the legislation by introducing a new speed threshold not used in any other part of the EU type-approval process. Draft

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11 Possible options for amendment of Regulation (EU) 2015/68

A comprehensive range of policy options have been identified and assessed (see Section 8). It is possible to summarise those detailed findings against the three criteria upon which the investigation has focussed as follows:

 Technical Availability of ABS: In the majority of instances, systems are readily available for relevant agricultural vehicles.

 Applicability of ABS: Systems are applicable for use on relevant agricultural vehicles deemed likely to undertake agricultural transport operations on-road.

 Cost Benefit Analysis: The likely costs of ABS implementation are high and are unlikely to be outweighed by monetised savings resulting from reduction in casualty numbers during the 15 year evaluation period.

As demonstrated by the Cost-Benefit Analysis (Section 8), the European Commission has a wide range of alternative policy options regarding the imposition of a mandatory requirement for ABS on agricultural vehicles of 40 < Vmax ≤ 60 km/h. The selection of which, if any, Draftof the identified policy options to implement (and related timescales) is a matter for the Commission and the relevant regulatory committees, informed by the analysis presented in this report. Thanks largely to the current content and structure of Delegated Regulation (EU) 2015/68 (RVBR), the text of the regulation may be amended to accommodate any of the proposed options (see Table 8.1). The regulation currently specifies the vehicles to which ABS shall be fitted in Annex I / Section 2.2.1.21 (for Category Tb) and Annex I / Section 2.2.2.16 (for Categories R3b, R4b & S2b).

11.1 Agricultural Tractors (Category Tb)

The ABS introduction dates for Category Tb vehicles of 40 < Vmax ≤ 60 km/h are currently specified by Annex I / Section 2.2.1.21.2. The alternative policy options and associated modifications required to the RVBR text are as follows:-

 Mandatory ABS on all 40 < Vmax ≤ 60 km/h Tb vehicles (Options 0, 4 or 5): o No changes to text required.

 No ABS on any 40 < Vmax ≤ 60 km/h Tb vehicles (Options 1, 2 or 3): o Delete Section 2.2.1.21.2 of Annex 1.

 Mandatory ABS on all 40 < Vmax ≤ 60 km/h Tb vehicles of MPM ≥ 11,500 kg (Options 6 or 7): o Specify an additional tractor Max Permissible Mass threshold value in Annex 1 / Section 2.2.1.21.2.

 Mandatory ABS on all Vmax > 50 km/h Tb vehicles (Options 8 or 9):

o Modify the vehicle Vmax criteria currently specified in Annex 1 / Section 2.2.1.21.2 to 50 < Vmax ≤60 km/h

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11.2 Agricultural trailers and interchangeable towed equipment (Categories R3, R4 & S2)

The RVBR currently does not contain any specific requirement for ABS implementation on Category R3b, R4b or S2b vehicles of 40 < Vmax ≤ 60 km/h, as ABS is only mandatory for such vehicles of Vmax > 60 km/h (see RVBR Annex I / Section 2.2.2.16). However, if it were deemed desirable to incorporate such a requirement for these vehicle types with 40 < Vmax ≤ 60 km/h capability, this Section could be modified in one of the following ways to reflect the policy options assessed by the investigation.

 No ABS on 40 < Vmax ≤ 60 km/h R3b, R4b or S2b vehicles (Options 0 or 1): o No changes to text required.

 Mandatory ABS on all 40 < Vmax ≤ 60 km/h R3b, R4b or S2b vehicles (Options 2, 4, 6 or 8):

o Modify the vehicle Vmax criteria currently specified in Annex 1 / Section 2.2.2.16 from Vmax > 60 km/h to Vmax >40 km/h.

 Mandatory ABS on all 40 < Vmax ≤ 60 km/h R3b, R4b or S2b vehicles of MPMaxles ≥ 12,000 kg (Options 3, 5, 7 or 9): o ModifyDraft the vehicle Vmax criteria currently specified in Annex 1 / Section 2.2.2.16 from Vmax > 60 km/h to Vmax >40 km/h and also specify an additional sum of technically permissible masses per axle (MPMaxles) threshold value. In practice this will only apply to R3 and some S2 vehicles as (by definition) R4 vehicles exceed the proposed mass threshold value.

N.B. It should be noted that the abovementioned policy options have been reviewed solely on a basis of technical and economic feasibility: their potential implementation date(s) have not been considered. However, the project team are unaware of any technical restrictions which would prevent the installation and use of ABS on a Category R or S vehicle when towed by a Category T vehicle which is not fitted with ABS. The trailer / towed equipment ABS requires an electrical power supply from the tractor and it is desirable for a warning light to be installed within the tractor cab to indicate correct functioning of the trailer system, but all these components may be retro-fitted to an existing / non-ABS tractor without difficulty. Consequently there are no practical restrictions upon the introductory timescale of ABS for Category R or S vehicles of 40 < Vmax ≤ 60 km/h.

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Acknowledgements The authors are grateful to the following:  Richard Cuerden for carrying out the technical review of the report;  Julie Austin for her assistance with project management;  Robert Hunt and Ryan Robbins for assistance in the development and management of the stakeholder surveys;  Lynne Smith and Caroline Wallbank for their assistance in the accident data analysis.  Those parties who responded to the stakeholder surveys  The industry bodies and manufacturers who participated in the stakeholder discussions and/or provided information and data.

References Allen, K. (2010). The effectiveness of ABS in heavy truck tractors and trailers. Washington: Us Department of Transportation National Highway Traffic Safety Administration . Bende, J., & Draft Kuhn, M. (2011). Risk of tractors in road traffic. Berlin: The German Insurance Association (GDV). (www.unece.org/fileadmin/DAM/trans/doc/2013/wp29gre/GRE-69-02.pdf). CEMA. (2013). CEMA position on the draft regulation on braking for tractors and the need for a balanced regulatory approach on ABS. Brussels: CEMA. (http://cema- agri.org/sites/default/files/publications/CEMA%202013%2006%2027%20- %20CEMA%20position%20on%20ABS%20for%20tractors.pdf). CEMA. (2015). Road Accidents with tractors: main problem is older machinery (Press Release). Brussels: CEMA. (http://cema-agri.org/publication/road-accidents- tractors-main-problem-older-machinery). CEMA. (2016a). Towed farm vehicles: Trailer or interchangeable equipment? Retrieved June 2017, from CEMA website: http://www.cema-agri.org/page/towed-farm- vehicles-trailer-or-interchangeable-equipment CEMA. (2016b). Examples of vehicle category R: trailers and S: interchangeable towed equipment. Agricultural vehicle categories under 167/2013 (for optional EU type approval) (PT26 - 2016 05 12 - V7). Brussels: CEMA. (http://cema- agri.org/sites/default/files/CEMA%20PT26%20-%202016%2005%2012%20- %20V7%20catalogue%20CEMA%20design%20R%26S.pdf). CEMA. (2017). 5 major factors causing more than 80% of on-road accidents with farm machines. Brussels: CEMA. (http://cema- agri.org/sites/default/files/publications/CEMA%20Press%20Release%20Analysis% 20accident%20data%20ag%20machinery%20Switzerland%20FINAL%2012%200 6%202017.pdf). Department for Transport (UK). (2016a). Road Safety Data. Retrieved from Data.Gov.UK: https://data.gov.uk/dataset/road-accidents-safety-data Department for Transport (UK). (2016b). Reported road casualties Great Britain 2015. London: Department for Transport. DfT. (2015). Impact Assessment: Increasing the agricultural tractor and trailer speed and combination weight limits. London: UK Department for Transport. Dodd, Bartlett, & Knight. (2006). Provision of information and services on the subject of the performance requirements, testing methods and limit values for braking

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systems of agricultural and forestry tractors, their trailers and interchangeable towed machinery - final report. Crowthorne: TRL Unpublished project report for the EC. European Commission. (2009). Impact assessment guidelines SEC(2009)92. Brussels: European Commission. European Commission. (2017). Statistics - Accident data. Retrieved from European Commission: Mobility and Transport: Road Safety: https://ec.europa.eu/transport/road_safety/specialist/statistics_en European Community. (2003). Directive 2003/37/EC of the European Parliament and of the Council on type-approval of agricultural or forestry tractors, their trailers and interchangeable towed machinery, together with their systems, components and separate technical units. Official Journal of the European Union, L 171/1 (9th July 2003). European Community. (2009). Regulation (EC) No 78/2009 of the European Parliament and of the Council of 14th January 2009 on the type approval of motor vehicles with regard to the protection of pedestrians and other vulnerable road users. Official Journal of the European Union, L35/1(4th February 2009). European Union. (2013). Regulation (EU) No 167/2013 of the European Parliament and of the Council on the approval and market surveillance of agricultural and forestry vehicles. Official Journal of the European Union, L 60. European Union.Draft (2014). Directive 2014/45/EU of the European Parliament and of the Council of 3rd april 2014 on periodic roadworthiness tests for motor vehicles and their trailers and repealing Directive 2009/40/EC. Official Journal of the European Union, L127/51 (29th April 2014). European Union. (2015). Commission Delegated Regulation (EU) 2015/68 supplementing Regulation (EU) 16/2013 of the European Parliament and of the Council with regard to vehicle braking requirements for the approval of agricultural and forestry vehicles (RVBR). Official Journal of the European Union, L17. European Union. (2016). Agriculture in the European Union and the Member States - Statistical factsheet. Brussels: European Commission, DG Agriculture and Rural Development, Economic Analysis Unit. European Union. (2016). Agriculture in the European Union and the Member States - Statistical factsheet. Brussels: European Commission. Eurostat. (2017). Database - Eurostat. Retrieved June 2017, from Eurostat: Your key to European statistics: http://ec.europa.eu/eurostat/data/database FHWA. (2000). Comprehensive truck size and weight study. Washington: United States Department of Transportation Federal Highway Administration. Forkenbrock, G., Flick, M., & Garrot, R. (1999). A comprehensive light vehicle antilock brake system test track performance evaluation. Society of Automobile Engineers SAE 1999-01-1287. Gotz, S., Holzer, J., Winkler, J., Bernhardt, H., & Engelhardt, D. (2011). Agricultural Logistics - system comparison of transport concepts in grain logistics. Landtechnik, 66(5), 381-386. Gotz, S., Zimmerman, N., Engelhardt, D., & Bernhardt, H. (2014). Influencing factors on agricultural transports and their effect on energy consumption and average speed. Agricultural Engineering International: CIGR(May), 59-69. Greenan, M., Toussaint, M., Peek-Asa, C., Rohlman, D., & Ramirez, M. (2016). The effect of roadway characteristics on farm equipment crashes: a geographic information systems approach. Injury Epidemiology, 3:31.

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Harkey, D., & Mera, R. (1994). Safety Impacts of different speed limits on cars and trucks. Washington: US Department of Transportation Federal Highway Administration. Helman, S. (2013). How do we know what we are doing is working? (Presentation). (National Fleet Driver Trainers Conference 2013). Retrieved from http://www.airso.org.uk/wp-content/uploads/2016/04/2013-Fleet-Shaun- Helman.pdf Hynd, D., McCarthy, M., Carroll, J., Seidl, M., Edwards, M., Visvikis, C., et al. (2015). Benefit and Feasibility of a Range of New Technologies and Unregulated Measures in the fields of Vehicle Occupant Safety and Protection of Vulnerable Road Users. Luxembourg: Publications Office of the European Union. doi:10.2769/497485. Jorgensen, C., & Persson, M. (2013). The Market for Tractors in the EU: Price differences and convergence. Brussels: Factor Markets Working Paper No 35. Kahane, C., & Dang, J. (2009). The long term effect of ABS in passenger cars and LTVs. Washington: US Department of Transportation, National Highway Traffic Safety Administration. Knight, I. (2001). A review of fatal accidents involving agricultural vehicles or other commercial vehicles not classified as a goods vehicle, 1993 - 1995. Crowthorne: TRL Limited. Knight, I. (2001). A review of fatal accidents involving agricultural vehicles or other commercialDraft vehicles not classified as a goods vehicle, 1993 - 1995. Crowthorne: TRL Limited. Knight, I. M. (2007). Positioning agricultural vehicle safety in the context of all accidents involving large vehicles (Presentation). (HSE Agricultural Vehicle Workshop, 15th November 2007). Retrieved from http://www.hse.gov.uk/aboutus/meetings/iacs/aiac/transport/151107/vehiclesafe ty.pps Knight, I., & Broughton, J. (2010). Techjniques for assessing the effectiveness of vehicle primary safety features using accident data. Crowthorne: TRL Published Project Report PPR201, TRL Limited. Knight, I., Robinson, T., Neale, M., & Hulshof, W. (2009). The road safety performance of commercial light goods vehicles. Brussels: European Parliament, Transport and Tourism Committee. Kraftfahrt-Bundesamt. (2016). Fahrzeugzulassungen (FZ 25) - Statistik. Statistische Mitteilungen des Kraftfahrt-Bundesamtes. Mederle, M., Urban, A., Fischer, H., Hufnagel, U., & Bernhardt, H. (2015). Optimisation potential of a standard tractor in road transportation. LandTechnik, 70(5), 194- 202. Miedema, J. (2003). The Effectiveness of Mandatory Motor Vehicle Safety Inspections: Do they save lives? Simon Fraser University. Moore, T. (2015). Anti-lock brakes for fast tractors. Landwards - Jornal of the Institution of Agricultural Engineers, Vol. 70(2), pp22-25. NAAC. (2017). Survey of Members. Peterborough: National Association of Agricultural Contractors, Confidential Report. Nathanson, A., Scarlett, A., & Barlow, T. (2014). Assessment on the availability of technology allowing vehicles of categories T2, T4.1 and C2 to fulfil Stage IV emission limts. Brussels: European Commission. Neeley, G., & Richardson, L. (2009). The effect of state regulations on truck crash fatalities. American Journal of Public Health, 99: 408-415.

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NHTSA. (2016). U.S. DOT advances deployment of Connected Vehicle Technology to prevent hundreds of thousands of crashes (13th December 2016). Retrieved from NHTSA Press Releases: https://www.nhtsa.gov/press-releases/us-dot-advances- deployment-connected-vehicle-technology-prevent-hundreds-thousands Richards, D. (2010). Relationship between speed and risk of fatal injury: pedestrians and car occupants. London: UK Department for Transport. Rizzi, M., Strandroth, J., Kullgren, A., Tingvall, C., & Fildes, B. (2015). Effectiveness of motorcycle antilock braking systems (ABS) in reducing crashes, the first cross- national study. Traffic Injury prevention, 16(2), 177-83. Scarlett, A. (2009). In-service assessment of agricultural trailer and trailed appliance braking system condition and performance - HSE Research Report RR697. Bootle, U.K.: Health and Safety Executive (HSE Books). Scarlett, A. (2013). Agricultural tractors - Chassis design and transmission solutions. Holme Hale: Scarlett Research Ltd, Confidential Contract Report No. 3266. Scarlett, A. (2015). Agricultrual tractors - Development of technical objectives for structural engine design. Holme Hale: Scarlett Research Ltd Confidential Contral Report No. 3273. Scarlett, A. (2015). Factors affecting the sale of 50 km/h agricultural tractors in the United Kingdom. Holme Hale: Scarlett Research Ltd Confidential Contract Report No. 3281. Scarlett, A. (2016).Draft Agricultural Tractors - Development of technical objectives for structural engine design - Phase 2. Holme Hale: Scarlett Research Ltd Confidential Contract Report No. 3282. Scarlett, A., Harding, P., & Wyatt, A. (2010). 'Look Behind You' - a guide to trailed equipment braking. Peterborough, UK: AEA. Seidl, M., Hynd, D., McCarthy, M., Martin, P., Mohan, S., Krishnamurthy, V., et al. (2017). In depth cost-effectiveness analysis of the identified measures and features regarding the way forward for EU vehicle safety: Final report. Luxembourg: Publications Office of the European Union. doi: 10.2873/748910. Smith, T., Couper, G., Donaldson, W., Neale, M., & Carroll, J. (2005). Seatbelt performance in quarry vehicle incidents. HMSO Norwich: Health and Safety Executive HSE RR406. Taylor, M., Lynam, D., & Baruya, A. (2001). The effects of drivers' speed on the frequency of road accidents. Crowthorne: TRL Report 421. United Nations. (2014). Regulation Number 13-H Braking of road vehicles. Geneva: www.unece.org.

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Annex 1 REVIEW OF ALTERNATIVE MEASURES In the questionnaires and meetings with industry, a range of other safety measures were proposed as possible alternatives to anti-lock braking systems (ABS) for agricultural vehicles (See Section 5.3.3). These numbered nineteen in total and are listed below:  Braking measures already in Regulation (EU) 2015/68 (RVBR), e.g. compatibility bands.  Control of trailer braking system via drive stick input (Continuously-Variable Transmission - CVT)/vehicle travel speed control.  Seat Belts.  Roll-Over Protective Structures (ROPS).  Electronic Braking Systems (EBS) for trailers.  Vehicle to Vehicle Communication.  Electronic Stability Control (ESC) for towing vehicles.  Improved Lighting/Signalling.  Improved conspicuity.  Improved field of vision for tractor driver (e.g. mirrors, close proximity or junction cameras,Draft blind spot proximity alarms).  Driver assist systems – collision warnings or avoidance systems.  Improved maintenance & roadworthiness checks.  Driver training/education (for drivers of both agricultural vehicles and other vehicles). The main body of the report has shown the general relationships between increased speed and collision probability, consequences and types. It has also shown how accidents involving loss of control (e.g. skidding and jack-knifing) collision risk increases with speed and how this is particularly relevant for agricultural tractors (Section 4.3). It showed how ABS works and its effectiveness at helping to prevent skidding and jack- knife accidents at higher speeds (Section 5.2). The main body of the report also reviewed the current accident data and exposure data, to quantify the occurrence of this type of collision (Section 4.3). The data showed that much of past accident data will be dominated by an agricultural vehicle fleet not capable of speeds in excess of 40 km/h, depending on year and country. Thus, the jack-knife collisions that have been occurring will in many cases be caused not by high speed but by other problems, such as braking imbalances between tractor and trailer. However, as a higher speed capability penetrates the fleet, then the expectation would be that jack-knifes caused by locked wheels at higher speed and not by braking imbalances would occur in future unless ABS was fitted to control this risk. Thus, it can be considered that the aim of ABS is to limit the future impact of that specific increase in skidding and jack-knife that may be associated with the increasing on-road use of tractors with a speed capability between 40km/h and 60 km/h. Increase speed has been documented to have a range of other impacts on safety that would not be influenced by ABS Thus, when considering alternative measures to ABS, each can be categorised as follows:  Direct alternative: A safety measure that aims to control the same safety risk as ABS just using a different approach or mechanism.  Indirect alternative: A measure that does not substantially affect the population of collisions likely to be influenced by ABS, but which affects any other part of the crash population.

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ABS is a well-known and understood technology that has been around in non-agricultural markets for decades. Our analysis has suggested that mature production systems will be available to agricultural vehicles in almost all relevant categories by the time the RVBR requires mandatory installation. The potential market maturity of each of the alternative measures will be considered wherever possible. Accident data has identified the relevant target population of accidents that might be influenced by ABS and consideration has been given to how effective it might be within that target population. Published information is available concerning other populations of agricultural vehicle collisions8, where possible the approximate size of the target population of each measure has been identified in comparison to ABS and, where quantifiable in easily accessible published literature, its effectiveness within that target population. However, this is only a preliminary analysis and has not researched each subject exhaustively.

Annex 1.1 Braking measures already in the RVBR Details of this measure were not provided by the respondents. However, it is assumed that it relates to requirements in the revised RVBR to greatly improve the overall braking performance of both tractors and trailers and to add requirements to ensure substantial improvements in the compatibility of the tractor and trailer in their braking characteristics. These measures are recent and, therefore, will not have been present in much of the past accident data reviewed and they also affect collisions similarly, that is, improving stopping distanceDraft and reducing the likelihood of jack-knife. However, these features have been directly assessed in the main cost benefit analysis, through the exclusion from the target population for ABS of jack-knife collisions that occurred as a result of brake system defects and imbalances where they involved tractor trailer combinations not capable of speeds in excess of 40 km/h. This is because of the evidence (Dodd, Bartlett, & Knight, 2006) showing that in the absence of braking imbalances, jack-knife at speeds below 40 km/h did not develop significant angles because the vehicle stopped before there was time for it to occur. Even in the absence of such imbalances, jack-knife would still occur at speeds greater than 40 km/h in the absence of ABS. Thus, the measures already in the RVBR have been accounted for in the calculation of benefits and costs of ABS. Given that they are already a mandatory requirement, they cannot now be considered an alternatively to ABS.

Annex 1.2 Control of trailer braking system via drive stick input (CVT Transmission/vehicle travel speed control Although details of the proposal were not received, it is expected that this measure is intended to provide improved matching of tractor and trailer braking levels to improve the compatibility of towed combinations. As such it partially targets the same group of casualties as ABS and also the existing compatibility corridors in the RVBR. However, it represents a different approach. Better matching of tractor and trailer braking will help to reduce the chance of wheel lock by ensuring the braking required for a given deceleration is distributed appropriately between tractor and trailer. However, it cannot prevent wheels locking when emergency braking is applied or when the road is very slippery. Implementing such a system would be likely to require sensing of deceleration and/or sensing of the coupling forces applied between tractor and trailer to identify how hard the trailer is braking and to control appropriately. It will not be as effective as ABS at preventing jack-knife and trailer swing but it may help in some circumstances. It will do nothing to aid steerability of the vehicle under braking. The cost of the system is unknown.

8 See for example (Knight I. , 2001), (Dodd, Bartlett, & Knight, 2006), (Knight I. M., 2007)

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Annex 1.3 Seat belts Seat belts are a proven benefit to safety in other road vehicles and have been made mandatory in agricultural vehicles within Reg. (EU) No 1322/2014. This Regulation requires fitment of lap belts as a minimum standard but 3 point lap diagonal belts are also permitted. One of the primary benefits of seat belts in road accidents is the protection of occupants in a severe frontal collision. (Knight I. , 2001) found that this was not a common crash type resulting in the death of tractor occupants. Most tractor occupants were killed either when struck from the rear by another large vehicle such as a heavy goods vehicle (HGV), or where a tractor rolled over. When heavy vehicles collide with the rear of an agricultural vehicle, it is common for the agricultural vehicle occupant to be ejected through the rear window, which is a significant contributor to the severity of injuries received. The primary restraint in a rear impact is actually the seat back. Historically, most agricultural vehicles would have a low seat back to maximise occupant manoeuvrability within the cab. Such low seat backs offer little restraint in the event of a rear collision. Using a high seat back designed to perform well in rear collision, similar to passenger car seats, would, therefore, have benefits. However, such seats will deform in the event of an impact and this can allow the occupant to ramp-up the seat back which could potentially still allow partial ejection or even simply a head collision with roof or rear structures. In this situation, the use of a seat belt would help prevent the ramping up action. A simple lab belt, well secured around the hips would be adequate to achieve this action. This is already a requirement and may, therefore,Draft act to improve the outcome for tractor drivers in this collision type, depending on the standard of the combined seat and restraint system. (Smith, Couper, Donaldson, Neale, & Carroll, 2005) studied the effectiveness of seat belts in quarry vehicle rollover incidents. This research found that a simple lap belt helped prevent ejection but allowed the occupant’s head to move around extensively within the cab, thereby coming into contact with various cab structures which were often not designed with the prevention of head injury in mind. Thus, severe injury could still occur. The use of a 3-point seat belt improved the situation and a 4 point, 3 inertia reel harness designed specifically for use in off-road machines improved the restraint even further. Although designed for quite different purposes the cab designs of the quarry vehicles and agricultural vehicles was not radically different and it is likely, therefore, that many of the results are transferrable. Thus, in this situation, the recent requirements would be expected to improve the outcome in rollover collisions but further gains may be possible with more sophisticated restraints.

Annex 1.4 Roll-Over Protective Structures (ROPS) As stated above, rollover is one of the leading causes of death for the occupants of agricultural vehicles in road collisions and it is understood that more rollovers occur on the farm. Maintaining a ‘survival space’ for the occupant is, therefore, an essential part of protecting those occupants and this is what ROPS are intended to do. However, as discussed above, ROPs will only be effective if the occupant stays within the structure and does not suffer heavy collision with the structure or with other hard objects within the structure. Thus, occupant restraint and seat belts are also an important part of the protection. ROPs have been mandatory on most new agricultural vehicles in most Member States for 30 years or more and they are now a mandatory part of EU Type Approval. Unless there is evidence that these are not working as intended, further requirements on new vehicles may have limited benefit. (CEMA, 2015) have suggested retrofitting ROPS to older tractors not equipped with them. It is understood some Member States have implemented this sort of action in the past. Whether this is a cost effective measure for those that haven’t already done so will depend strongly on how feasible it is to retrofit effective structures (including consideration of occupant restraint) to old vehicles, how

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much it will cost per vehicle and how many vehicles not already equipped with the protection remain in use. Whilst a laudable and potentially effective safety initiative, it should be noted that the target population of such activities is existing ‘in-service’ vehicles, whereas the requirements of EU type-approval legislation apply only to new vehicles when first placed on the market. Thus, this solution cannot be implemented through the type approval system.

Annex 1.5 Electronically controlled braking systems (EBS) for trailers Electronically controlled braking systems (EBS) have been available in the commercial HGV market for many years and are now the norm in that market. The basic concept of the system is that traditional truck brakes use air, which is a compressible fluid. HGVs can be long with as much as 15 m or more distance between the foot pedal and the rearmost axle brake. The air pressure wave from a rapid application of the foot brake therefore takes a finite time to reach the brake chamber to the rear and this could mean that full emergency braking would not be achieved for up to as much as 0.75 to 1 second after pedal application. In an EBS system the wheel brake is still applied by air pressure but that air is stored locally. The air is controlled locally using an electro-pneumatic valve. The signal to brake is still carried from the foot valve to the axles pneumatically but this is to provide a mechanical back-up only. In parallel to this, the signal is carried electronically to the near the wheel such that it is transmitted almost instantaneously, thus reducing brake reaction time and stopping distances. A spin off benefitDraft of this development was that the hardware now existed to fully control the brake pressure both in terms of reduction and increase in pressure. This has led to a range of additional brake control functions being incorporated within EBS systems. For example, all HGV EBS come equipped with ABS functions as standard. Some will have some form of coupling force control, aimed at equalising braking between tractor and trailer. Many also come with roll stability control functions, which requires only additional sensing of lateral acceleration and additional software code. Where trailers are air braked, similar brake reaction time and stopping distances may be expected, perhaps slightly lower due to generally shorter lengths. The benefits of additional electronic control over the brakes could also be significant. However, the system will require many of the same components as standard ABS and possibly some additional ones. It is, therefore, likely to be more beneficial than ABS but also more costly.

Annex 1.6 Vehicle to Vehicle (V2V) Communication V2V communication is not, in and of itself, a safety system; it is merely an enabling technology. The information that you choose to communicate between vehicles and what action the vehicle chooses to take based on that information is what determines the effect on safety. Thus, there is a wide range of different safety applications, e.g. (NHTSA, 2016), that aim at warning the driver or intervening in driving in order to stop a potential collision from occurring. These can include a variety of ‘junction assist’ systems aimed at preventing collisions at intersections and it is thought that this is the type of system that is intended by industry respondents referring to this as an alternative measure. It is, therefore, clearly an indirect alternative to ABS, aimed at preventing or mitigating a different crash population to ABS. There is considerable overlap between active safety systems and assisted and automated driving systems enabled by V2V communication and those enabled by on-board sensors such as radar, Lidar and cameras. The advantage of V2V is that it does not rely on line-of sight and potentially has a longer range. Thus, it can ‘see’ hazards that the on-board sensors cannot, giving earlier warning of potential crashes, enabling better levels of avoidance. However, the disadvantage is that it will only work where the potential collision partner is also equipped with the same technology. Firstly, this requires considerable standardisation effort across different sectors of industry (Original

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Equipment Manufacturers (OEMS), Tier 1 suppliers in agricultural vehicles, passenger cars, goods vehicles, motorcycles, etc.). Secondly, the effectiveness of the technology does not increase linearly with fitment. If a vehicle is equipped with a crash avoidance system based on on-board sensors, then the driver immediately gets the full benefit of that safety system in all situations in which it is designed to function. However, when a vehicle is equipped with a crash avoidance system based on V2V technology, it only gets the benefit of that technology when it encounters another vehicle with that technology. Until fitment is common in the fleet, then other equipped vehicles may be encountered only rarely such that early adopters do not see the benefits. Mandatory fitment may be required to overcome this barrier. The costs and benefits of such systems are not yet well developed and will be highly variable based on the type of enabling technology used and the use that is made within each vehicle and the market penetration rate. The potential for junction assist systems, whichever technology is used to enable them, is high for agricultural vehicles. (Knight I. , 2001) showed that more than half of car occupants and motorcyclists killed in collision with agricultural vehicles were killed when the agricultural vehicle was turning right (left for mainland Europe) either into, or out of, a side road. Two crash avoidance systems could conceivably help substantially in these situations:  A system that prevents the vehicle pulling out from a T-junction if a collision is likely with an approaching vehicle. This could be implemented through the transmission by stopping acceleration, or through the brakes by stopping motion (or both). The former is possible because the vehicle would be stationaryDraft when the automated action was implemented.  A system preventing the vehicle turning from the main road across the path of an oncoming vehicle in the opposite lane and/or a vehicle overtaking from the rear. In this case, the vehicle is often already moving at the point the turn commences so in this case, avoidance action through the brakes would be necessary. At a minimum, this would require brake actuation and control valves similar to ABS to automatically apply the brakes independent of the driver. Where higher speeds are involved on larger roads, it is likely that ABS would be necessary to ensure that the automated braking action did not have adverse consequences in terms of braking stability, particularly in low friction conditions. This is analogous to the situation for passenger cars. UNECE Regulation 13-H (as amended) (United Nations, 2014) does not make ABS mandatory for passenger cars. However, the pedestrian protection regulation, Regulation (EC) No 78/2009 (European Community, 2009), makes it mandatory for passenger cars to be fitted with brake assist systems which boost braking over and above that demanded by the driver if it detects it as an emergency braking application. UNECE Regulation 13-H governs the standard for brake assist systems and requires that, if such systems are fitted, the vehicle must also be equipped with ABS. In terms of maturity, no current production vehicles (car, truck, or bus) use the form of V2V communication envisaged, though rulemaking to introduce it is proposed in the USA. Volvo were first to market with a ‘turn across path’ collision avoidance system (based on forward looking radar and camera) on the 2015 XC90. Very few other vehicles are equipped with this sort of system. Some vehicles (e.g. Mercedes E class) are equipped with automated braking systems that work when crossing a cross roads at speed. This is also the scenario most commonly envisaged for V2V communication. However, this is typically an urban crash type and was not cited as a common agricultural type by (Knight I. , 2001). No current production systems will prevent a vehicle emerging from a T- Junction. Thus, in summary, the potential for this type of system is strong within agricultural vehicles but it does not directly mitigate the same group of accidents as ABS. It is not yet clear which of several competing technical ways of implementing the system will be best. The market maturity of systems is extremely low compared to ABS and, in some

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applications at least, ABS is likely to be a pre-requisite of a system. The effectiveness of vehicle to vehicle communication will rely on widespread fitment across all other vehicle types that agricultural vehicles encounter. At this stage, the proposal is too vague to allow cost benefit analysis.

Annex 1.7 Electronic Stability Control (ESC) for towing vehicles ESC is a mature system, mandatory for most road vehicles including passenger cars and HGVs. In road vehicles ESC controls two risks – that of directional instability (e.g. spinning) as a result of excessive steering, and rollover as a consequence of cornering too fast. In agricultural vehicle collisions, there are relatively few examples of spinning as a consequence of excessive steering (as opposed to locked wheel braking). Thus, the main focus would be on rollover. In its implementation on heavy goods vehicles, EBS and therefore ABS are technical pre- requisites of fitting the system because the system must be able to activate the brakes, potentially each individual wheel brake separately, without driver intervention and very rapidly. The system must be able to do this safe in the knowledge that these automated brake applications will not cause locked wheel braking instabilities, even if the road surface is slippery, which explains why ABS is a pre-requisite. ESC is likely to be a substantial benefit in on-road rollovers which (Knight I. , 2001) found to represent about 10% of on-road agricultural vehicle fatalities but (CEMA, 2017) found to represent 24% of on road accidents, 39% of on-road fatalities and 51% of all accidents when both road and field were considered. The reason for the difference in proportions identifiedDraft is not known, however, the studies used different methodologies, in different countries and both involved relatively small sample sizes. It is also worth noting that it is possible that many off-road rollovers occur not just because of a high centre of gravity and cornering too fast but because of other factors such as traversing across steep slopes or sliding sideways and then ‘tripping’ in mud. The system may require significant development to be effective in this type of circumstance which is not prevalent in other road vehicles. Unlike ABS alone, the engineering assessment that ESC will be effective is fully borne out in retrospective statistical studies in other road vehicles. In fact, the study of ABS (Kahane & Dang, 2009) which found it not very effective in passenger cars found that adding ESC in a combined ABS/ESC transformed it from a system without a statistically significant effect to one that was a major contributor to large scale fatality reduction. Thus, it can be summarised that ESC in agricultural vehicles would be likely to come with ABS by default and would extend the benefits of ABS significantly. It would be likely to cost more than ABS alone but the additional amount may not be that great because relatively little additional hardware would be required. Although stakeholders specifically referred to this measure for towing vehicles, in some cases it may only be a trailer that overturns and it is perfectly technically feasible to fit it to a trailer independently of the towing vehicle.

Annex 1.8 Improved Lighting/Signalling (Knight I. , 2001) found that more than half of car occupant and motorcycle fatalities occurring in collision with an agricultural tractor, involved the tractor making some form of right turn at the time (equivalent to a left turn in mainland Europe). This group was divided between those where the tractor was emerging from a side road or field onto the main road and those where they were leaving the main road and turning into a side road of field. Improved signalling will mainly be relevant to those where the tractor was turning off the road and it collided with road users overtaking it who failed to see the direction indicators. This is a significant crash type but only a subset of the above, further reduced by the fact that the driver failed to use the direction indicators in some of those collisions.

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Similarly, a proportion of other road users were killed when they collided with the rear of a slower moving vehicle and some of those were in dark conditions with poor or defective lighting. Improving lighting as an aid to conspicuity in those cases also has potential, provided that it is maintained such that it remains effective in service including after use in dirty harsh conditions. If it could be maintained 100% defect free then (Knight I. , 2001) estimated that improved lighting and signalling could potentially save the lives of around 20% of car occupants and 15% of motorcyclists killed in collision with agricultural vehicles. In principle, this is a greater casualty benefit that ABS offers. However, it should also be noted that (Knight I. , 2001) found that significant numbers of agricultural vehicles did suffer from contributory defects and that a large proportion of these related to the lighting system. Thus, the potential benefit highlighted here may be substantially less than indicated unless complementary measures to ensure continued function in service were introduced.

Annex 1.9 Improved conspicuity (by means other than lighting) Improving conspicuity by means other than lighting would probably not have much effect on the turning accidents but may affect those where drivers collided with the rear of an agricultural vehicle because they failed to see it. It can also form a partial backup if lighting is poor as a consequence of inadequate maintenance. Typically, measures are based on the use of retroflective tape. However, this does itself require maintenance. If covered in thickDraft mud it will not be effective. Annex 1.10 Improved field of vision for tractor driver (e.g. mirrors, close proximity or junction cameras, blind spot proximity alarms) (CEMA, 2017) found driver visibility to be a factor influencing the cause of 15% of collisions. By contrast (Knight I. , 2001) did not report any issues with respect to agricultural vehicle field of view in any of the 41 fatalities studied. However, improved field of vision can be considered in several different contexts. Two of the more important are typically:  Field of view in close proximity manoeuvring.  Field of view when emerging from junctions. HGVs suffer considerable difficulties in close proximity manoeuvring. They are large tall vehicles and tend to have blind spots around the vehicle such that pedestrians and cyclists can be hidden from view as the vehicle reverses, turns corners and pulls away from rest. This results in a substantial number of fatalities. However, in studying this problem, it has been found that increasing the number of blind spot mirrors may not have been as effective a solution as thought, possibly because of driver workload and the time taken to look in each mirror and direct view during a complex manoeuvre and possibly because the images of vulnerable road users in those mirrors could be small and distorted. Research has found that vulnerable road users seen in direct vision through a glazed area were identified substantially quicker than those only visible through a mirror. Similar concerns can be applied to camera systems that add to the number of places the driver needs to look or are complex or difficult for the driver to scan and detect the hazard. (Knight I. , 2001) identified no collisions involving agricultural tractors on the road in this kind of manoeuvring scenario. However, it may be much more of an issue in the farm environment, where the vehicle may, for example, be manoeuvring around a yard with pedestrians moving around it. The driver of an agricultural vehicle can be seated a long way rearward of the front of the vehicle, particularly if ancillary equipment is mounted to the front at the time. Where the field of view when emerging from a junction is restricted, this can make it difficult for the tractor driver to see traffic approaching on the main road. (Knight I. , 2001) did identify

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several collisions relevant to this situation and, therefore, there may be benefits in cameras or mirrors specifically designed to help drivers see in this situation, subject to analyses of workload etc. However, it should also be noted that field of view issues in such cases can also relate to field exits or junctions sited close to bends such that it is the bend that restricts the field of view and such devices would have no benefit. In each of these cases, passive devices such as mirrors and cameras rely on drivers to use them properly and humans have been shown to be fallible in this respect. Cameras are now used in some applications more as a sensor than a field of view aid such that pattern recognition software can identify collision threats and either warn the driver to bring it to their attention more directly, or to intervene automatically to reduce the probability or severity of collision. These have strong potential to be more effective

Annex 1.11 Driver assist systems – collision warnings or avoidance systems In the passenger car, HGV and bus market, advanced driver assist systems are being developed at an exponential rate in order to warn drivers of collision risks or, increasingly, to intervene independent of the driver. Applications include, but are not limited to:  Forward collision warning.  Automated emergency braking.  Lane departureDraft warning.  Lane keep assist.  Emergency lane keeping.  Blind spot information system.  City turn assist.  Junction assist systems/start inhibit. As discussed in the section relating to vehicle to vehicle communication (Annex 1.6), these systems have tremendous potential to improve safety. Those relating to assistance at junctions to prevent agricultural vehicles turning across the path of other vehicles would be particularly relevant. However, the systems are relatively new in the passenger car market, are more immature in the commercial vehicle market and do not exist at all, to the authors’ knowledge, in the agricultural vehicle market. At present, road going versions are all based on sensors mounted on the vehicle, typically cameras, radar and or Lidar. The most sophisticated passenger cars, such as a Mercedes S class for example, may now be fitted with multiple cameras all around the vehicle, ultrasonic sensors front and rear, two forward looking radars and four corner radars. If the difference in cost between passenger car ABS and agricultural vehicle ABS is representative of the difference in cost between Advanced Driver-Assistance System (ADAS) sensors in each market then the cost of such systems will be extremely high in the agricultural vehicle market.

Annex 1.12 Improved maintenance & roadworthiness checks (Knight I. , 2001) found that 12% of agricultural vehicles involved in fatal collisions had a contributory defect. This is entirely consistent with the 13% found by (CEMA, 2017). Improved maintenance and roadworthiness checks do have significant potential to improve safety. However, it must be borne in mind that even in industries where the maintenance of the vehicle is highly regulated with regular inspections, such as HGVs and buses, there is still a proportion of accidents where defects are a contributory factor. For example, in around 6% of HGVs involved in fatal accidents and around 3% of light goods vehicles, at least one contributory defect was found (Knight, Robinson, Neale, & Hulshof, 2009). In addition to this, researchers in North America have often questioned

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whether mandatory periodic inspection regimes are effective (see for example (Miedema, 2003)). Thus, while the potential for improvement is strong, it may not result in casualty reduction as large as suggested by the base figures showing how often defective vehicles contribute to collisions, particularly given the harsh environment that agricultural vehicles operate in and the practical difficulties that may be involved with a mandatory inspection regime across a sparsely populated rural area. It should also be noted that requirements to maintain vehicles and check their roadworthiness cannot be implemented through the type approval system, which specifies only the requirements that new vehicles must meet before they can be registered for use on the road. As such, they can be used to ensure systems are designed in a way that enables easier or more effective roadworthiness checks, for example, requiring self-diagnostic tests and warning lamps if systems are not working.

Annex 1.13 Driver training/education (for drivers of both agricultural vehicles and other vehicles) Some form of human error is a contributory factor in most collisions and those involving agricultural vehicles are no exception. Thus, driver training appears a very logical and promising solution to the problem. However, while a huge amount of training is undertaken, there is little objective and rigorous analysis of the effectiveness of that training. Thus, at the very least, there is an absence of evidence of the effectiveness of training. Where studies have taken place, the results vary according to the type of training. WithDraft respect to most new driver training and to post license training interventions there is no evidence for an overall effect on the number of casualties, e.g. (Helman, 2013). While in some cases, effective training may simply lack robust evidence of effect, in others there is direct evidence of no effect. Some promising techniques have been emerging in more recent years. For example, there is strong evidence that graduated driver licensing can reduce casualties and hazard perception training and testing has evidence to suggest an 11% reduction in crashes whilst some fleet safety initiatives are backed by some evidence. Thus, while training does have potential it is not necessarily an easy or cheap solution and is much more complex than it may appear. In particular, training other vehicle drivers to respond correctly to encounters with agricultural vehicles, which for many drivers will happen extremely rarely, may involve high costs in relation to the benefits. It should also be noted that requirements to train drivers cannot be implemented through the type approval system, which specifies only the requirements that new vehicles must meet before they can be registered for use on the road.

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doi:10.2873/580390