German comments on RDE proposal
I. General comments:
Germany – as other Member States - supports the Commission’s proposal on RDE.RDE is the most important measure to further reduce the real-world emissions of regulated pollutants, and especially of NOx and particle number, from Euro 6 vehicles.The RDE requirements should be implemented as currently planned by the European Commission in a two step approach, starting with a monitoring phase in September 2015 complemented by an application of Not-to-exceed limits in 9-2017/9-2018.
II. Comments to the text
a) Annex IIIa
Germany proposes to amend the text of Annex IIIA (as presented in TCMV on 15th October)as outlined in the attached document and has the following additional/explanatory comments:
2.5:
Germany supports the approach outlined under 2.5 to ensure that vehicles should not be designed in such a way that independent RDE testing could be avoided or at least complicated by the design of the vehicle or the after-treatment systems. Following the general principles of the Euro 5/6 Regulation it should be possible also for Member States or 3rd parties to carry out RDE testingindependently. It should be mentioned here that this argument was a mainbasis for relevant decisions in the RDE exercise, e.g. for the usage of an “RDE family approach”.
It shouldbe mentioned here that also testing carried out by Member States or independent 3rd parties has to follow dedicated rules to be defined in Regulation (EC) No. 692/2008, especially when challenging type approvalsgranted under this Regulation. As concluded from the discussions of the RDE-LDV working group the necessary discussions of these requirements should take place in the context of the later RDE packages and Germany is looking forward to contribute also to these discussions.
4.2:
Germany asks for further clarification why such “flexibility requirements” are seen to be necessary asit would becomenecessary to define dedicated technical parameters to avoid that all vehicles become “particular vehicles” for which normal testing conditions (for driving routes and payloads) are considered to be incompatible. It should therefore be evaluated whether 4.2 could be deleted.
4.7 + 9.8 + 9.13:
Germany supports the conclusion of the RDE-LDV working group of 8th September 2014 to foresee one evaluation tool for checking the compliance with NTE limit values.Based on current knowledge and experiences this could be the EMROAD tool. Nevertheless CLEAR should additionally be used for monitoring purposes. If further analyses provide a basis for reconsideration of the application of the evaluation tools a revision should be possible. Both tools (EMROAD and CLEAR) could be further analysed and improved.
6.2:
The focus of RDE is to reducereal-driving emissions especially under urban conditions. Thereforealso the order of the trips should be fixed as “Urban -> rural -> motorway”. Possible discussions between type approval authorities and manufacturers on a different order of the trips should be avoided to preventpotential different applications of the Regulation and this way to ensure level playing field.
Based on experiences from Euro VI legislation Germany supports the proposal to clarify that “rural operation” may also include short periods of urban driving when driving through urban areas.
6.8:
An average speed of “at least 20 km/h” for urban operation could lead to inappropriate “urban driving conditions”, as e.g. also average speeds around 50 km/h would be allowed. It is appropriate to avoid too low average speeds with too much idling but also artificially high average speeds. Therefore a range of adequate average speeds could be foreseen. Some experiences with PEMS test show that a range of 15-30 km/h seems to cover urban driving conditions appropriately.
6.9:
Germany considers an additional speed range to be covered for motorway driving to be generally helpful to avoid too low speeds on motorways. Therefore thedefined speed range could e.g. take into account the maximum allowed speed but then also the local regulatory speed limits.
The requirement of 10 minutes constant driving at 110 km/h seems not necessary and should be deleted.
6.11:
The proposed number seems to be quite high. It should be evaluated whether this additional requirement is necessary.
6.12+9.12:
To be discussed in the context of the decision on a “maximum speed limit”.
9.9:
It seems currently not yet clear whether additional dynamic boundary conditions for trip verification could become necessary and helpful to further improve the work of the RDE evaluation tools and to better avoid extreme driving. Based on current stage of discussions on this issue it seems appropriate not to foresee a placeholder for such additional requirementsalready now in the Regulation.Nevertheless such additional parameters should be further discussed and - if appropriate – included at a later stage.
b) Appendix 1
ECU data/surveillance testing:
Germany is of the opinion that fortype approval the use of some vehicle ECU data, except for ECU exhaust gas flow data, may generally be allowed if it can be robustly shown that the collection of ECU data does not influence the vehicle emissions or performance, as requested in Annex IIIa, No. 4.6. The requirement of Annex IIIa, No. 4.6, is fullysupported in that context. Further it is necessary to apply a dedicated procedure - at least for each relevant parameter with regard to the final result- showing that the ECU data is correct and robust.Further it needs to be maintained that fully independent testing (without ECU data) is possible.
For surveillance testing (as e.g. ISC)Germany supports the view to generally allow the usage ofECU data also for the exhaust gas flow, as it could be restricting to obligatorily equip customer vehicles with EFM. Nevertheless also here it needs to be ensured that the used ECU data is correct and robust and that the collection of ECU data does not influence the vehicle emissions or performance.