Wednesday, 31 May 2017

RDE for Light-Commercial Vehicles ACEAs view on current discussion

RDE FOR LIGHT-COMMERCIAL VEHICLES

AGENDA

1. Initial type-approval for multi-stage vehicles (MSV)

2. In-service conformity (ISC) for multi-stage vehicles

3. Boundary condition ‘v x apos’ for light commercial vehicles

4. Other boundary condition, which affect the validity of a RDE test

INITIAL TYPE-APPROVAL FOR MULTI-STAGE VEHICLES (MSV)

The OEM has to specify physical limits, which within the emission type approval is valid for subsequent manufacturers

The physical limits are parameters for mass, frontal area and rolling resistance

No changes to after-treatment system

The OEM has to build up a ‚maximum vehicle‘

The ‚maximum vehicle‘ shall specify the physical limits, and perform a RDE test

The ‚maximum vehicle‘ is included into the PEMS family

Current approach suggested by the European Commission

INITIAL TYPE-APPROVAL FOR MULTI-STAGE VEHICLES (MSV)

Support of specifying physical limits

Limitations on these physical limits do not suffice

Air resistance is not fully taken into account (shape of the frontal area)

Cooling/ Ventilation through the radiator grille affects engine thermodynamics

ACEA proposes to allow OEMs the possibility to define further parameters

ACEA disagrees with the idea of a maximum vehicle only built for verifying MSVs in the PEMS family.

Lack of practicality for MSV manufacturer and OEM

Additional environmental burden through useless building of ‘maximum vehicle’

The final MSV will have to perform RDE test during in-service conformity, therefore the maximum vehicle is useless for the ISC procedure. Furthermore is not economically viable.

Position of ACEA

ACEA proposes the vehicle for the RDE emission type approval will be selected among the vehicles belonging to the concerned PEMS family in accordance with the type approval authority.

IN-SERVICE CONFORMITY (ISC) FOR MULTI-STAGE VEHICLES

Current process for in-service conformity of MSV

Check ISC family

compliance

Investigation of TAA

& Body builder

IN-SERVICE CONFORMITY (ISC) FOR MULTI-STAGE VEHICLES

Current approach regulates the responsibility of the OEM and the Mulit-stage vehicle manufacturer

RDE tests with the result of ‚RDE < 1.5*NTE‘ pass successfully and are not considered for the in-service conformity family

RDE tests with the result ‚RDE>1.5*NTE‘ will be investigated. Depending on the fulfillment of the boundary conditions the Multi-stage vehicle manufacturer or the OEM is responsible

Current approach presented by the European Commission

ACEA fully supports the approach of the European Commission

NTE = Not-to-exceed limit

BOUNDARY CONDITION ‘V X APOS’ FOR LIGHT COMMERCIAL VEHICLES

Equivalent to the boundary condition ‚v x apos‘ for passenger cars there will be an additional ‚v x apos‘ for light commercial vehicles

The European Commission is currently evaluating such a boundary condition

ACEA already submitted a proposal and provided evidence with data from Heinz Stevens database

The Department for Transportation handed in own test results from surveillance testing

Current approach of the European Commission

BOUNDARY CONDITION ‘V X APOS’ FOR LIGHT COMMERCIAL VEHICLES

Proposal of ACEA regarding v*apos boundary condition

BOUNDARY CONDITION ‘V X APOS’ FOR LIGHT COMMERCIAL VEHICLES

Collation of available data

BOUNDARY CONDITION ‘V X APOS’ FOR LIGHT COMMERCIAL VEHICLES

The data of the DfT is statistically not reliable since these are just seven trips

The DfT declared their test drives as driven in a ‚typical manner‘, but as we can see one trip is even above the passenger car limit. This implies by definition an agressive driving

Two test drives with the same vehicle differ widely in their results, which suggests that at least one trip was not driven in ‚a typical manner‘

Position of ACEA

ACEA recommends keeping the criteria originally proposed for weakly motorized vehicles

BOUNDARY CONDITION ‘V X APOS’ FOR LIGHT COMMERCIAL VEHICLES

Position of ACEA

*Same car characteristics

BOUNDARY CONDITION ‘V X APOS’ FOR LIGHT COMMERCIAL VEHICLES Furthermore… integrating 95th %ile data from DfT to original ACEA proposal

*Same car characteristics

OTHER BOUNDARY CONDITION, WHICH AFFECTS THE VALIDITY OF A RDE TEST

The niche features and usage of these vehicles makes both laboratory (WLTP) and RDE

testing set-up almost impossible. There are not a full set of representative WLTP values for these vehicles to have a proper

reference value to be used for the post-processing of the RDE data The scope of Regulation 2017/xxx covers vehicles of categories M1, M2, N1 and N2 with a

reference mass not exceeding 2 610 kg (2840 kg) (Same limit of scope of 715/2007) RDE testing requires specific boundary conditions applicable to these vehicles specificities.

Approach

Exemption of MSV, which maximum WLTP test mass is above 2840 kg shall be exempted of performing ISC.

Background

* “Borco-Höhns GmbH&Co.KG“ www.borco de

SUMMARY

The physical limits are feasible, but the OEMs should have the possibility to define further parameters

ACEA proposes the vehicle for the RDE emission type approval will be selected among the vehicles belonging to the concerned PEMS family in accordance with the type approval authority

The definition of the procedure for MSV during ISC is reasonable and feasible

The criteria for ‘v x apos’ originally proposed for weakly motorized vehicles should be kept

The niche features and usage of MSV, which maximum WLTP test mass is above 2840 kg, entails an exemption of performing ISC.