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Australian Model 3 Waiting Room
- Thread starter rgc1990
- Start date
Not a subject expert (and I could be entirely wrong) but I believe the issue here is that since the car is complied as a five-seat passenger vehicle it does not comply with five-seat passenger-car regulations ie should the use of a child seat be positioned in the centre of the middle rear seat, there needs to be an appropriate location for an anchorage point to enable the child seat to be secured.
I dont feel that is correct mate, unless laws have changed since I bought my SSV in 2017?
That car only had the centre mount included as standard, although there is provision for 2 others on the outside seats.
I couldn't use the middle one (2 baby seats), so had to purchase the brackets from Holden and bolt them onto the parcel shelf.
There was only one car seat mount installed when the car rolled off the line.
e-enthusiast30
Member
Yeah I believe the legislation link inserted earlier was amended in 2019. Might explain why older cars don't have it and don't have to comply.
richardnau
Member
OK, let's try to sort this out.
For my sins, I used to spend a lot of time reading technical standards for electrical safety, electromagnetic compatibility, etc. (for consumer and professional AV gear). Let me see if I can sort through ADR 34/3.
Tesla Model 3 is a category MA vehicle. So this standard applies.
Upper tether points must be provided for every seating position set out in Clause 6:
Clause 6 tells us which seats require tether points:
Basically: all seats in second row should have tether points, except:
6.1.1.1: the middle seat where the seat back is divided into two or more sections ... and the division lies substantially along the 'Seating Reference Plane' of the middle seating position
6.1.1.2: a seating position where it's a folding seat, and placing a child's seat would limit access to rear seats - so if you have three rows of seats, (not M3) you can have an exemption under some circumstances for seats in the middle row.
To understand whether 6.1.1.1 applies, we;ll need to understand the definition of 'Seating Reference Plane'. That's not defined in ADR 34/3, so we'll need to look to the other standards referenced in ADR 34/3:
We find as follows:
(I) clearly does not apply (driver's seat).
(II) likewise does not apply.
(III) does not apply - refers to single seats only.
(IV) must therefore be the definition we're looking for. The only part that COULD apply is 'the plane nominated by the Manufacturer' (as the middle seat is not an outboard seat).
So at this point we are kind of stumped - because we don't have a copy of Tesla's submission docs. But we can hypothesise. My hypothesis would be that the 'Seating Reference Plane' for the rear middle seat would be a vertical, longitudinal (length-wise) plane through the centre of the middle seat.
That being the case, we then need to understand how the seat split works in M3.
It's a 60/40 folding seat. It's not split in the middle.
On that basis, I would suggest that the exemption set out in 6.1.1.1 does not apply. There is no split substantially along the seating reference plane. Therefore each seating position in the back of the M3 should have a compliant anchor point.
Tesla's own Owner's Manual is confused about what's actually in the car (viewing the manual for Highland cars, the Au version).
This pic suggests NO anchor point exists for the middle seat:
So does this:
These ones suggest that there IS a middle tether:
My bush lawyer skills (ha!) suggest that M3 SHOULD have an upper tether in the middle position. But I have no visibility of Tesla's approval submissions and of any exemptions they may have been granted. For example, the fact that the 'arm-rest' includes the head-rest (attached) may have given rise to some form of exemption (because the head-rest is not fixed in place).
I recall the situation with the Atto 3 (cited earlier) and it seems very similar! Will be very interesting to see how this unfolds.
The more I think about it, the more I think it likely that there's some form of exemption (because of the way that the arm-rest works). I suspect they'll tidy up the documentation to remove all reference to centre tethers and that the approval papers will specify no top-tethered seats to be used in the centre rear position. But that's pure speculation. If anyone can dig up the approvals documents, they'd make interesting (?) reading.
And finally: where's my VIN?
Attachments
Holy crap. My head is londitudely spinning across my geometric centre after reading that.
Im glad it makes sense to you.
Elon would say - Bring me the person who wrote that and explain what it means. haha
probably short, non value adding posts like this one.
e-enthusiast30
Member
Ladies and Gentlemen, I'm honoured to introduce you to our new resident Lawyer/Legal Rep for this thread... @richardnau *round of applause*
Great post mate.
Is there any kind of anchor point in the centre under/behind the head rest?
richardnau
Member
hahaha. Lionel Hutz
I prefer to think of myself as more of a Bunsen Honeydew (from Muppet Labs - where the future is being made today).
richardnau
Member
I can only go by reports from others and the documentation - all of which suggest that the answer is no.... well, at least not one that is exposed for use.
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Funny cos I read that this morning, and too went searching for the the “reference plane” documentation.
Indeed the rear 60/40 seat fold does take the whole of the middle seat with it. So it does not comply with the exception.
More importantly though, and this is what would suggests to me they have messed up with early deliveries. Is that the parcels shelf does have a tether point for the middle seat! The car does have three attachments welded to the rear shelf for child seats. But the parcel shelf only has the holes and cover for two of them. Just weird. Almost as if they forgot to add it, being the first Aussie cars built.
richardnau
Member
I've just been reading Highland Owner's Manuals for various other markets (Europe, UK). They all have the same confusing documentation that we see in the Au version: explicitly showing only two tether points, but implying a third (by showing how to install a child seat in the centre position.
I'm not ruling out the possibility that Tesla have made a big mistake with cars for Australia. Unless we can view the documentation submitted for type approval, and any documentation setting out exemptions, it's all speculation.
I spent a few minutes looking at the photo posted in the other thread (Australian Model 3 Highland experiences, tips, tricks) but I can't figure out what I'm looking at and where the three points have been provided in the structure...
I think the only answer is for us to be expeditiously be sent our cars so we can have a look for ourselves.
If you have 3 kids going in the back, send it in for the mods, if not, lets go cruising and get on with life
PcS000
Member
I'd like to receive my final invoice...When i payed out my current NL i had to call the bank and they did the transaction over the phone as it was too big to do online.
Wasnt NAB tho, one of the smaller banks
PcS000
Member
Yeah, is was quite difficult getting a pic. It is dark under there and hard to get an angle.
But this it taken from the left of the car, with the seats folded down. It shows the left and the centre tether point. There is another on the right side, not in frame. But when viewed from above the parcel shelf there isn’t an opening for the middle one.
