Draft regulation Impact Statement for Underrun Protection a draft statement inviting discussion and comments from parties affected by the proposed heavy commercial vehicle safety initiative January 2007 Report Documentation Page


Economic Aspects of Underrun Protection: Benefit-Cost Analysis



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Economic Aspects of Underrun Protection: Benefit-Cost Analysis

It is difficult to estimate many of the economic costs that Underrun Protection (UP) would impose on the construction, operation and maintenance of heavy heavy commercial vehicles. A number of different factors have to be taken into account and their influence is complex to analyse.


Costs for provision of Underrun Protection



Front Underrun Protection
General
The design of typical rigid front Underrun Protection (UP), including that designed to meet UNECE R93, is of traditional “brackets and beam” construction. Such a system is primarily connected to the chassis beams, but also to foot-steps and lamp brackets. Despite the range of available chassis heights, the front UP height should not deviate beyond certain limits. This in turn necessitates a flexible production system with a modular arrangement for the brackets. The product development phase would need a few person-years of work input, during which it would be necessary to test the front UP according to the legislative requirement.
Generally, manufacturers need between 20 and 50 tests to develop a conforming prototype. Additionally, in the product/assembly verification phase, further testing would be needed. An estimate is that this entire activity would cost not more than $4 million. This would be amortized over 100,000 to 250,000 heavy commercial vehicles until a front end redesign was undertaken for the updated model.. Over and above development and engineering costs is the marginal production cost, which is more difficult to estimate. Material prices and manufacturing cost may range from $300 to $400 for each UP device. Aggregating development, material and production costs, the cost for rigid front UP, fitted to a new heavy commercial vehicle and complying with UNECE R 93, has been estimated at $440 per vehicle (See Appendix 6 for details). Other estimates have previously put this cost at from a low of $100-150 (Haworth 2002) to a high of $1000-4000 (NTC 2005). Although the former appears to represent manufacturing costs only, and the latter covers the costs of retrofitting to all vehicles, it would be prudent to include a sensitivity analysis on front UP cost as part of any benefit-cost analysis.
Cost due to added mass
The materials used in typical rigid front UP include a steel front UP beam and steel brackets, all of which is covered with styled plastics This is the standard look for today’s heavy commercial vehicles. A number of metal alloys may be used, adapted to the strength requirements and production methods. The added mass of the front UP can be 50-80 kg, depending on factors such as the chassis height and construction details.

This mass may be located three quarters of a metre in front of the front axle(s) for a typical bonneted vehicle and between a metre and a metre and a half for a typical cab-over vehicle. The cantilever effect of this mass about the front axle(s) could then give a total effect of up to 110 kg added to the front axle(s) (with a corresponding 30 kg reduction from the rear axle(s)). This total effect is based on a worst case of a cab-over design with wheelbase of about 4 metres and front overhang of about one and a half metres1.


One potential issue with this additional load on the front axle(s) follows on from the state and territory 6 tonne steered axle limit. In Europe, steered axle limits vary from 10.5 tonnes in the UK to 13 tonnes in France. The most observed limit in countries of the European Union is 11.5 tonnes. The added mass on a vehicle’s front axle(s) from front UP, as well as increases in mass in meeting the latest engine emission standard (Euro 4), may become a problem for European heavy commercial vehicle makers supplying in to Australia.
The National Transport Commission (NTC) have estimated that raising the steered axle limit by 500 kg (to 6.5 tonnes) would more than offset such effects, while still allowing for improvements in cabin strength. Whether the limit would or should be raised is beyond the scope of this RIS. However, the potential loss in productivity and higher running and maintenance costs due to the additional mass of UP should be considered as part of any benefit-cost analysis. An indicative assessment of this has been made later in this RIS.
Future developments in other safety devices, such as UP with energy absorbing systems and deflection zones, would likely lead to further increases in the mass of existing UP, Consideration of this is again beyond the scope of this RIS. Any future proposal to fit advanced UP would be assessed on its merits at the time.
Cost due to added length
Unless part of the vehicle structure, energy absorbing UP typically increases the length of a vehicle. Rigid UP typically does not. The rigid UP covered by UNECE R93 allows for a maximum longitudinal distortion of 400mm. This distortion may occur without involving the remainder of the front of the vehicle and so rigid UP may be mounted almost flush with the front of the vehicle. Therefore, there is no need to estimate a cost relating to legally available lengths of heavy commercial vehicles. An exception to this may be where a vehicle structure has not been originally built to accept UP and it has to be added on to the front in a similar way as a bull bar. Vehicle or bull bar manufacturers are asked to comment on this by way of the feedback forms at the start of this RIS.
Side Underrun Protection
The costs for rigid side Underrun Protection (UP) for a range of rigid heavy commercial vehicles and articulated heavy commercial vehicles depend on the vehicle length and so are variable. These are presented in Table 7 (See Appendix 6 for details). For rough purposes only, if the relative number of the different vehicle lengths in the fleet is taken in to account, an average cost of $847 would result (a more sophisticated calculation was used for the benefit-cost analysis). The material used for construction of the systems is generally aluminium, although steel may also be used.
Table 7: Cost of rigid side UP for rigid heavy commercial vehicles and articulated heavy commercial vehicles


Vehicle Type

Cost

Side UP

3 axle semi-trailer

$872

5 axle semi-trailer

$872

6 axle semi-trailer

$872

7 axle B-Double

$1,147

8 axle B-Double

$1,147

9 axle B-Double

$1,147

Double Road Train

$1,675

Triple Road Train

$2,455

2 axle rigid commercial vehicle

$574

3 axle rigid commercial vehicle

$574

4 axle Twin-Steer rigid commercial vehicle

$574

2 axle rigid commercial vehicle with 2 axle dog trailer

$872

3 axle rigid commercial vehicle with 3 axle dog trailer

$872

Fleet average

$847

Source: VBG (component supplier), Sweden and Scania, Sweden



Rear Underrun Protection
Systems for rear Underrun Protection (UP) are available in simple, foldable and removable types. The cost of the simple type has been estimated at $773 vehicle (See Appendix 6 for details). The cost for foldable and removable types is high and the foldable versions can be twice that of a simple system.
Some alternative estimates for side and rear UP are shown in Table 8. The estimates include the variation in costs arising from the use of steel and aluminium and foldable and detachable types of rear UP. This table has been included to again demonstrate the importance of including a sensitivity analysis on protection system cost as part of any benefit-cost analysis.
Table 8: Cost for rigid type UP to UNECE regulations or EEC Directives


Front UP* (incremental cost over normal bumper bar)

$440

Side UP** (for a 3 axle semi-trailer)

$1600

Rear UP** (Aluminium beam)

$310#

Rear UP** (Steel beam)

$450#

Rear UP** (Mounting assembly fixed type)

$470

Rear UP** (Mounting assembly detachable type)

$650

Rear UP** (Mounting assembly foldable type)

$2300

*Supplied by commercial vehicle maker,

**Supplied by specialist manufacturer, adjusted for c.i.f. prices and industry profitability



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