Discussion paper Albus / Steininger 17.12.2010

Worldwide harmonized Light vehicle Test Procedure – WLTP

DTP (Development of the Test Procedure)

DHC (Development of a Harmonized Cycle)

(A) - Status of WLTP project

·  After the withdrawal by Mr. Gauvin and the USA, the informal group WLTP and the sub-group DTP are without chairmanship. Mr. D’Urbano (Switzerland, BAFU) is appointed as DTP chair (co-chair by India). A confirmation by Mr. D’Urbano is expected on 20st of December.

·  WP.29 / AC.3 will reassess the WLTP situation in June 2011. This needs to be prepared by GRPE at the meetings in January and June. An interim discussion will be possible at WP.29 meeting in March.

·  At the GRPE session in January it’s necessary to achieve a situation where we have a clear view on following points:
-- status of WLTP project (DTP, DHC)
-- timeschedule and workplan
-- difficulties (technical issues)
-- political issues (to be raised at WP.29 in March)

·  The several sub-groups (5) of DTP have started work after GRPE meeting in June – with differing progress up to now. Especially the sub-group “lab-process EV/HEV” is delaying. Early in the process we need to decide how to proceed. There are following options:
(1) Stress work and activities, so that sub-group “lab-process EV/HEV” comes in line with WLTP timeschedule.
(2) Switch to an 2-step approach, where the EV/HEV part will be adopted later as an GTR amendment by WP.29 / AC.3 (maybe 1 or 2 years later). In that a case an important condition will be, that the basic WLTP GTR is developed in such a way, that the needs of measurement of EV/HEV vehicles are already taken into account. Only specific requirements and definitions for EV/HEV measurement will be added later.
(3) The EV/HEV part will be repealed from WLTP project, and will be continued on national/regional level. For Europe this will be an EU-Regulation, or the amendment of ECE regulations 83, 85 and 101. With such an approach a worldwide harmonisation will be impossible for some time.

Comment Steininger:

The Commission currently is preparing a study by an external contractor, with the following contents:

1. Identification of tests to be performed and parameters to be measured a type approval for EV/HEV, e.g.:

- Pollutant emissions

- Electric and fuel consumption / CO2 emissions

- Electric range

- Battery charging time

at low (- 7° C) / intermediate (10° C) / warm (20° C) temperatures

- Durability of batteries (charging cycles)

…

The guidance for identifying the elements should be the need to give an appropriate picture of the environmental performance and the purpose-oriented utility of the EV/HEV. In addition, the information must be differentiated enough and presented in such a way that it allows for an educated purchasing choice by the consumer based on the real performance of the EV/HEV.

2. Develop feasible concept of how the elements identified under 1) could be tested and measured at type approval. Hereby the costs and benefits of the tests have to be taken into account. The results should be fed into the work of the WLTP-DTP group as a European contribution. Therefore the concepts must be developed to a detail, which allows a clear view of the steps to be performed, the resources needed and results to be expected by the WLTP-DTP group. However, the drafting of a final regulatory text of the GTR is not part of this specific agreement.

The results of this study should be fed into the WLTP-DTP work (as an European contribution) or in a separate European development for EV/HEV specific process (if option (3) pointed out above becomes reality).

(B) - EU activities required concerning the measurement of CO2 emissions and fuel- / electric energy- consumption (“CO2”)

1. General

In the background of the WLTP project there are several basic, strategic and conceptual issues, which needs to be considered on a European level. This should happen very early in the process, because the conclusions will influence the input from EU to the WLTP process, and it’s a precondition to negotiate compromise solutions with the other Contracting parties and involved NGO’s. The main topic in this regard is the measurement of “CO2”. Beside the aim of harmonization, in this field the WLTP project has mainly the following three purposes and targets:

·  Improved Reproducability (robust procedure)

·  Improved Representativity (reflecting real world CO2-emissions, fuel-/energy consumption)

·  Finalisation of DTP and DHC in 2013 (adoption by WP.29 / AC.3)

These are very important issues, because it can be expected that the value of “CO2”, determined with WLTP procedure during type approval, will be taken in future as basis for several measures like CO2-regulation, taxation, consumer information (labelling), etc.. In this regard several frame conditions will influence the WLTP development and negotiations to find compromises. Therefore early discussions and clarification are needed concerning the following issues or questions.

2. Pre-assessment / research projects

Several parameters of DHC and DTP will influence the test results – either increase or decrease. This needs to be pre-assessed. Results from research projects should be evaluated (e.g. projects in Germany).

Comment Steininger:

The Commission appreciates the ongoing German study and is waiting for its results.

It could also be envisaged that the JRC looks into this matter, e.g. by consolidating existing research available and possibly doing own tests.

3. Cycle parts / weighting

It can be expected that WLTP (like WMTC) will end up with three cycle parts (low, medium, high speed). It should be considered very early if the necessary weighting of the three test results can be harmonised, or if a special weighting for Europe is needed.

Comment Steininger:

The current view of WLTP is that the test results are weighted in the same manner by all contracting parties (i.e. the weighting is defined in the GTR), possibly according to a functional dependence on vehicle parameters such as power/mass ratio etc. (if it can be established that e.g. "weaker" vehicles run predominately in urban areas etc.). It should also be noted that the cycle parts themselves eventually may be different for different vehicle categories (e.g. determined by the power/mass ratio) that preferably should also be defined in the GTR.

It is however possible that no international consensus can be reached on an international level and the weighting of the cycle parts and/or vehicle categories (if applicable) are not defined in the GTR. In such case Europe would have to come up with its own proposal for EU Regulation in a timely manner. It is therefore suggested that as soon as the "draft" cycle parts are established (probably around mid-2011), the EU-WLTP group develops a European position on their weighting and vehicle categories in order to define a EU position at WLTP level as well as a fall back solution for EU legislation.

4. Type approval issues

To provide robust and representative CO2 values with ECE approval and EU type approval, besides the test procedure (WLTP) several issues need to be improved (e.g. 4% range, family concept, mass definitions).

Comment Steininger:

The improvement of these issues should be done by the WLTP-DTP group.

Reply Albus:

Type approval issues are not covered by a GTR. They need to be defined and adopted with the transposition process of a GTR into EU type approval system, either with an ECE Regulation (new or amendment) or an EU Regulation. With the second TÜV study this field will also be investigated and assessed.

5. Assessment of “real world emissions” and comparison of “CO2” results / Correlation

The development of validation testing and the outcome of the comparison between NEDC and WLTP test results will lead to several questions. Does WLTP reflect European real world CO2 emissions? How can this be evaluated? If the CO2 emissions in WLTP are significant higher – what will happen concerning the 95 g/km target? If the CO2 emissions in WLTP are equal or significant lower – how can CO2 emissions be communicated – test result combined, 3 test results from the cycle part (range), with a „reality-factor“, with additional test-cycle results defined in Europe?

Comment Steininger:

Regulation 443/2008/EC on the reduction of CO2 emissions from passenger cars requires the setting of new CO2 targets (i.e. an adaptation of the 130 g/km CO2 emission target curve) after the introduction of a new test cycle in order to achieve the same level of environmental protection. Consequently a study has to establish correlation factors for the CO2 emission measured on the NEDC and the WLTP test cycle, probably along the lines of the study done for the correlation of the ETC and WHTC for heavy duty engines. Obviously such study can only look at generic differences of the emissions measured on the two test cycles, the emission differences of individual vehicle types may be lower or higher than the generic differences.

Reply Albus:

The possible impact of “WLTP” needs to be considered for regulated gaseous and particulate emissions at the same time.

6. “CO2” Approach

CO2 emissions measurement/approval – based on a „worst case approach“ or an „average value approach“?

Comment Steininger:

???

Reply Albus:

Yes, the question is not clear – I will explain a little bit. Regarding emission regulations the approval of a vehicle type covers some ranges or different cases (e.g. family concept, different masses, engine modes, fuels, …). Concerning pollutant and noise emissions in many cases a worst case approach is required, meaning that the worst case has to comply with the limit values. Aiming on realistic “CO2” values (see representativity, point 1.) the general question is, if the “worst case approach” should be applied, or if an “average value approach” is better, to express with the “CO2” value the average of a vehicle type. This point is linked to questions regarding the test procedure as well as to the type approval issues.

7. APU’s / MAC’s

What will be the approach concerning APU’s and MAC’s?

Comment Steininger:

In June 2009 it was decided by WP.29 not to deal with MAC issues in the context of WLTP.

For MAC the Commission is currently preparing a test procedure. After its regulatory implementation a numeric value describing the energy efficiency of the MAC within a specific vehicle will be available. The regulatory use of this information still has to be decided, basically there are two options available: (1) use of the MAC energy efficiency performance information in the context of Regulation 443/2009/EC, e.g. by some formula weighting CO2 emissions from the test cycle and from MAC use, (2) separate regulation of MAC energy efficiency.

Reply Albus:

The situation with MAC is quite clear. But other APU’s, consuming electric energy, are influencing also the “CO2” value. The issue of APU’s is also a part of the second TÜV study. A decision on the approach is needed. Several cases and modes need to be considered (APU active during test cycle, APU partly active during test cycle, APU active outside test cycle, APU as optional equipment, APU with different modes and activation (automatic, selection by driver). Possible approaches are:

·  Continue with the current approach

·  Extra measurement of the electric energy consumption of APU’s

·  Measurement of delta state of charge (battery)

·  Definition of some frame conditions concerning APU’s and electric energy consumption (DTP)

8. Eco innovations

What will bet he approach concerning eco innovations?

Comment Steininger:

The effect of eco innovations should be visible to the most possible extent in the CO2 emissions measured on the WLTP driving cycle. It is however likely that also the WLTP driving cycle will still have to be complemented by specific test elements assessing certain eco innovations.