acea rde lessons learned status 05/2017 - europa · acea lessons learned ... devices that require a...
TRANSCRIPT
ACEA
RDE Lessons Learned
Status 052017
31st May 2017
ACEA Lessons Learned
Member States shall ensure that vehicles can be tested with PEMS on public roads in accordance with the
procedures under their own national law while respecting local road traffic legislation and safety
requirements
Annex IIIA Paragraph 24
2
Member States shall ensure that vehicles can be tested with PEMS on public roads in accordance with the
procedures under their own the national law of the member state where the test is being conducted
while respecting local road traffic legislation and safety requirements
Argument Clarification of the regulation to be applied
Example TNO should perform a RDE test in Germany under the regulation of Germany not under the regulation of the Netherlands
Revised text
Definition of ai is missing
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters and units
ACEA Lessons Learned
3
Argument Argument ai is used in Section 4 of Appendix 6
Revised text
(Copy from Regulation (EU) 2016427)
ACEA Lessons Learned
] Pdrive = 70[kmh]36(7919+073[N(kmh)]70[kmh]+003[N(kmh)sup2](70[kmh])sup2+1470[kg] 045[mssup2])0001
Annex IIIA Appendix 6 Paragraph 342
4
7066[kmh]36(7919+073[N(kmh)]7066[kmh]+003[N(kmh)sup2](7066[kmh])sup2+1470[kg]
0454[mssup2])0001
Argument
Inconsistent with ldquoACT WLTP after ISC V11final - cleanrdquo of December 2016
Argument Inconsistent with ldquoACT WLTP after ISC V11final - cleanrdquo of December 2016
Revised text
Backup
5
ACEA RDE lessons learned
A number of Lessons Learned issues were raised at the COM workshop on 1718th January 2017
bull Several of these have not been addressed by Package3
bull ACEArsquos review ndash facts amp questions ndash in following slides
Status 052017
6
ACEA Lessons Learned
Original text 6922008 Article 2 6
lsquoperiodically regenerating systemrsquo means catalytic converters particulate filters or other pollution control
devices that require a periodical regeneration process in less than 4 000 km of normal vehicle operation
Original text bdquoEU-WLTPldquo Annex XXI 381
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter
particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle
operation
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
7
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle operation
Revised text
ACEA Lessons Learned
Original text 6922008 Annex III 3134
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure
Original text bdquoEU-WLTPldquo Annex XXI Sub-Annex 6 -Appendix 1 12
During cycles where regeneration occurs emission standards need not apply If a periodic regeneration occurs
at least once per Type 1 test and has already occurred at least once during vehicle preparation it does not
require a special test procedure In this case this Appendix does not apply
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure If a periodically regenerating device has a
regeneration period in normal operation of greater than 4000 km it does not require a special test procedure
and the Ki factor may be set to 10 During cycles where regeneration occurs emission standards need not
apply If a periodic regeneration occurs at least once per Type 1 test and has already occurred at least once
during vehicle preparation it does not require a special test procedure In this case this Appendix does not
apply If a periodically regenerating device has a regeneration period in normal operation of greater than 4000
km it does not require a special test procedure and the Ki factor may be set to 10
Argument The current wording is somewhat illogical and frequently leads to misunderstandings The proposal
reflects the background to the requirements and maintains the concept that a system which regenerates
periodically (rather than continuously) is a periodically regenerating system but if the regeneration occurs every
cycle it will be considered in testing and requires no KI whereby a regeneration period of more than 4000 km
leads to negligible Ki factors which need not be determined
Revised text
ACEA Lessons Learned
Original text
Annex I Point 241 Figure I24
9
ArgumentRegarding PI vehicles PN requirements of RDE are not applied to mono fuel vehicles whose reference fuel is LPG NGBiomethane or Hydrogen Therefore they should be applied to bi-fuel vehicles and the vehicles should be tested with petrol only Regarding CI vehicles Type I test is conducted with B5B7 only Therefore RDE should be conducted with B5B7 only
Revised text
ACEA Lessons Learned
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Annex IIIA Paragraph 1216
10
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads
eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making
the necessary administrative arrangements If the respective PEMS test is not required by this Regulation
the manufacturer may charge a reasonable fee as set out in Article 7(1) of Regulation (EC) No 7152007
Annex IIIA Paragraph 24 - Renumbered to 25
11
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making the necessary administrative arrangements If the respective PEMS test is not required by this Regulation the manufacturer may charge a reasonable fee as set out comparable to the provision in Article 7(1) of Regulation (EC) No 7152007
Argument Article 7(1) is related only to repair and maintenance information
Revised text
ACEA Lessons Learned
New text (RDE 3)
3132 The manufacturer shall ensure that the information listed in point 31321 is made available on
a publicly accessible website without costs and without the need for the user to reveal his identity or sign
up The manufacturer shall keep the Commission and Type Approval Authorities informed on the location of
the website
31321 The website shall allow a wildcard search of the underlying database based on one or more of the
following
Make Type Variant Version Commercial name or Vehicle Identification Number as defined in the
Certificate of Conformity pursuant to Annex IX to this Regulation
The information described below shall be made available for all vehicles in a search
the results of the PEMS tests as set out in point 63 of Appendix 5 point 39 of Appendix 6 and point
4 of Appendix 7c for all vehicle emission types in the list described in point 54 of Appendix 7 For
NOVC-HEVs the results of the PEMS tests as set out in point 63 of Appendix 5 and if applicable
point 39 of Appendix 6 shall be reported For OVC-HEVs the results of the PEMS test as set out in
point 4 of Appendix 7c shall be reported
the Declared Maximum RDE Values as reported in point 482 of the Certificate of Conformity as
described in Annex IX of Directive 200746EC
Annex IIIA Paragraph 31321
12
31321 The website shall allow a wildcard search of the underlying database based on one or more of the following Make Type Variant Version Commercial name or Vehicle Identification Number Type Approval Number as defined in the Certificate of Conformity pursuant to Annex IX to this Regulation
ArgumentVIN does not have more information than Type Variant Version and Type approval number
Revised text
ACEA Lessons Learned
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test
family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described
in point 53 but with a warm engine
Annex IIIA Paragraph 45
13
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described in point 53 but with a warm engine with engine coolant temperature and engine oil temperature above 343 K
Argument Clarification
Revised text
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Member States shall ensure that vehicles can be tested with PEMS on public roads in accordance with the
procedures under their own national law while respecting local road traffic legislation and safety
requirements
Annex IIIA Paragraph 24
2
Member States shall ensure that vehicles can be tested with PEMS on public roads in accordance with the
procedures under their own the national law of the member state where the test is being conducted
while respecting local road traffic legislation and safety requirements
Argument Clarification of the regulation to be applied
Example TNO should perform a RDE test in Germany under the regulation of Germany not under the regulation of the Netherlands
Revised text
Definition of ai is missing
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters and units
ACEA Lessons Learned
3
Argument Argument ai is used in Section 4 of Appendix 6
Revised text
(Copy from Regulation (EU) 2016427)
ACEA Lessons Learned
] Pdrive = 70[kmh]36(7919+073[N(kmh)]70[kmh]+003[N(kmh)sup2](70[kmh])sup2+1470[kg] 045[mssup2])0001
Annex IIIA Appendix 6 Paragraph 342
4
7066[kmh]36(7919+073[N(kmh)]7066[kmh]+003[N(kmh)sup2](7066[kmh])sup2+1470[kg]
0454[mssup2])0001
Argument
Inconsistent with ldquoACT WLTP after ISC V11final - cleanrdquo of December 2016
Argument Inconsistent with ldquoACT WLTP after ISC V11final - cleanrdquo of December 2016
Revised text
Backup
5
ACEA RDE lessons learned
A number of Lessons Learned issues were raised at the COM workshop on 1718th January 2017
bull Several of these have not been addressed by Package3
bull ACEArsquos review ndash facts amp questions ndash in following slides
Status 052017
6
ACEA Lessons Learned
Original text 6922008 Article 2 6
lsquoperiodically regenerating systemrsquo means catalytic converters particulate filters or other pollution control
devices that require a periodical regeneration process in less than 4 000 km of normal vehicle operation
Original text bdquoEU-WLTPldquo Annex XXI 381
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter
particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle
operation
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
7
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle operation
Revised text
ACEA Lessons Learned
Original text 6922008 Annex III 3134
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure
Original text bdquoEU-WLTPldquo Annex XXI Sub-Annex 6 -Appendix 1 12
During cycles where regeneration occurs emission standards need not apply If a periodic regeneration occurs
at least once per Type 1 test and has already occurred at least once during vehicle preparation it does not
require a special test procedure In this case this Appendix does not apply
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure If a periodically regenerating device has a
regeneration period in normal operation of greater than 4000 km it does not require a special test procedure
and the Ki factor may be set to 10 During cycles where regeneration occurs emission standards need not
apply If a periodic regeneration occurs at least once per Type 1 test and has already occurred at least once
during vehicle preparation it does not require a special test procedure In this case this Appendix does not
apply If a periodically regenerating device has a regeneration period in normal operation of greater than 4000
km it does not require a special test procedure and the Ki factor may be set to 10
Argument The current wording is somewhat illogical and frequently leads to misunderstandings The proposal
reflects the background to the requirements and maintains the concept that a system which regenerates
periodically (rather than continuously) is a periodically regenerating system but if the regeneration occurs every
cycle it will be considered in testing and requires no KI whereby a regeneration period of more than 4000 km
leads to negligible Ki factors which need not be determined
Revised text
ACEA Lessons Learned
Original text
Annex I Point 241 Figure I24
9
ArgumentRegarding PI vehicles PN requirements of RDE are not applied to mono fuel vehicles whose reference fuel is LPG NGBiomethane or Hydrogen Therefore they should be applied to bi-fuel vehicles and the vehicles should be tested with petrol only Regarding CI vehicles Type I test is conducted with B5B7 only Therefore RDE should be conducted with B5B7 only
Revised text
ACEA Lessons Learned
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Annex IIIA Paragraph 1216
10
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads
eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making
the necessary administrative arrangements If the respective PEMS test is not required by this Regulation
the manufacturer may charge a reasonable fee as set out in Article 7(1) of Regulation (EC) No 7152007
Annex IIIA Paragraph 24 - Renumbered to 25
11
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making the necessary administrative arrangements If the respective PEMS test is not required by this Regulation the manufacturer may charge a reasonable fee as set out comparable to the provision in Article 7(1) of Regulation (EC) No 7152007
Argument Article 7(1) is related only to repair and maintenance information
Revised text
ACEA Lessons Learned
New text (RDE 3)
3132 The manufacturer shall ensure that the information listed in point 31321 is made available on
a publicly accessible website without costs and without the need for the user to reveal his identity or sign
up The manufacturer shall keep the Commission and Type Approval Authorities informed on the location of
the website
31321 The website shall allow a wildcard search of the underlying database based on one or more of the
following
Make Type Variant Version Commercial name or Vehicle Identification Number as defined in the
Certificate of Conformity pursuant to Annex IX to this Regulation
The information described below shall be made available for all vehicles in a search
the results of the PEMS tests as set out in point 63 of Appendix 5 point 39 of Appendix 6 and point
4 of Appendix 7c for all vehicle emission types in the list described in point 54 of Appendix 7 For
NOVC-HEVs the results of the PEMS tests as set out in point 63 of Appendix 5 and if applicable
point 39 of Appendix 6 shall be reported For OVC-HEVs the results of the PEMS test as set out in
point 4 of Appendix 7c shall be reported
the Declared Maximum RDE Values as reported in point 482 of the Certificate of Conformity as
described in Annex IX of Directive 200746EC
Annex IIIA Paragraph 31321
12
31321 The website shall allow a wildcard search of the underlying database based on one or more of the following Make Type Variant Version Commercial name or Vehicle Identification Number Type Approval Number as defined in the Certificate of Conformity pursuant to Annex IX to this Regulation
ArgumentVIN does not have more information than Type Variant Version and Type approval number
Revised text
ACEA Lessons Learned
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test
family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described
in point 53 but with a warm engine
Annex IIIA Paragraph 45
13
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described in point 53 but with a warm engine with engine coolant temperature and engine oil temperature above 343 K
Argument Clarification
Revised text
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
Definition of ai is missing
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters and units
ACEA Lessons Learned
3
Argument Argument ai is used in Section 4 of Appendix 6
Revised text
(Copy from Regulation (EU) 2016427)
ACEA Lessons Learned
] Pdrive = 70[kmh]36(7919+073[N(kmh)]70[kmh]+003[N(kmh)sup2](70[kmh])sup2+1470[kg] 045[mssup2])0001
Annex IIIA Appendix 6 Paragraph 342
4
7066[kmh]36(7919+073[N(kmh)]7066[kmh]+003[N(kmh)sup2](7066[kmh])sup2+1470[kg]
0454[mssup2])0001
Argument
Inconsistent with ldquoACT WLTP after ISC V11final - cleanrdquo of December 2016
Argument Inconsistent with ldquoACT WLTP after ISC V11final - cleanrdquo of December 2016
Revised text
Backup
5
ACEA RDE lessons learned
A number of Lessons Learned issues were raised at the COM workshop on 1718th January 2017
bull Several of these have not been addressed by Package3
bull ACEArsquos review ndash facts amp questions ndash in following slides
Status 052017
6
ACEA Lessons Learned
Original text 6922008 Article 2 6
lsquoperiodically regenerating systemrsquo means catalytic converters particulate filters or other pollution control
devices that require a periodical regeneration process in less than 4 000 km of normal vehicle operation
Original text bdquoEU-WLTPldquo Annex XXI 381
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter
particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle
operation
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
7
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle operation
Revised text
ACEA Lessons Learned
Original text 6922008 Annex III 3134
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure
Original text bdquoEU-WLTPldquo Annex XXI Sub-Annex 6 -Appendix 1 12
During cycles where regeneration occurs emission standards need not apply If a periodic regeneration occurs
at least once per Type 1 test and has already occurred at least once during vehicle preparation it does not
require a special test procedure In this case this Appendix does not apply
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure If a periodically regenerating device has a
regeneration period in normal operation of greater than 4000 km it does not require a special test procedure
and the Ki factor may be set to 10 During cycles where regeneration occurs emission standards need not
apply If a periodic regeneration occurs at least once per Type 1 test and has already occurred at least once
during vehicle preparation it does not require a special test procedure In this case this Appendix does not
apply If a periodically regenerating device has a regeneration period in normal operation of greater than 4000
km it does not require a special test procedure and the Ki factor may be set to 10
Argument The current wording is somewhat illogical and frequently leads to misunderstandings The proposal
reflects the background to the requirements and maintains the concept that a system which regenerates
periodically (rather than continuously) is a periodically regenerating system but if the regeneration occurs every
cycle it will be considered in testing and requires no KI whereby a regeneration period of more than 4000 km
leads to negligible Ki factors which need not be determined
Revised text
ACEA Lessons Learned
Original text
Annex I Point 241 Figure I24
9
ArgumentRegarding PI vehicles PN requirements of RDE are not applied to mono fuel vehicles whose reference fuel is LPG NGBiomethane or Hydrogen Therefore they should be applied to bi-fuel vehicles and the vehicles should be tested with petrol only Regarding CI vehicles Type I test is conducted with B5B7 only Therefore RDE should be conducted with B5B7 only
Revised text
ACEA Lessons Learned
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Annex IIIA Paragraph 1216
10
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads
eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making
the necessary administrative arrangements If the respective PEMS test is not required by this Regulation
the manufacturer may charge a reasonable fee as set out in Article 7(1) of Regulation (EC) No 7152007
Annex IIIA Paragraph 24 - Renumbered to 25
11
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making the necessary administrative arrangements If the respective PEMS test is not required by this Regulation the manufacturer may charge a reasonable fee as set out comparable to the provision in Article 7(1) of Regulation (EC) No 7152007
Argument Article 7(1) is related only to repair and maintenance information
Revised text
ACEA Lessons Learned
New text (RDE 3)
3132 The manufacturer shall ensure that the information listed in point 31321 is made available on
a publicly accessible website without costs and without the need for the user to reveal his identity or sign
up The manufacturer shall keep the Commission and Type Approval Authorities informed on the location of
the website
31321 The website shall allow a wildcard search of the underlying database based on one or more of the
following
Make Type Variant Version Commercial name or Vehicle Identification Number as defined in the
Certificate of Conformity pursuant to Annex IX to this Regulation
The information described below shall be made available for all vehicles in a search
the results of the PEMS tests as set out in point 63 of Appendix 5 point 39 of Appendix 6 and point
4 of Appendix 7c for all vehicle emission types in the list described in point 54 of Appendix 7 For
NOVC-HEVs the results of the PEMS tests as set out in point 63 of Appendix 5 and if applicable
point 39 of Appendix 6 shall be reported For OVC-HEVs the results of the PEMS test as set out in
point 4 of Appendix 7c shall be reported
the Declared Maximum RDE Values as reported in point 482 of the Certificate of Conformity as
described in Annex IX of Directive 200746EC
Annex IIIA Paragraph 31321
12
31321 The website shall allow a wildcard search of the underlying database based on one or more of the following Make Type Variant Version Commercial name or Vehicle Identification Number Type Approval Number as defined in the Certificate of Conformity pursuant to Annex IX to this Regulation
ArgumentVIN does not have more information than Type Variant Version and Type approval number
Revised text
ACEA Lessons Learned
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test
family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described
in point 53 but with a warm engine
Annex IIIA Paragraph 45
13
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described in point 53 but with a warm engine with engine coolant temperature and engine oil temperature above 343 K
Argument Clarification
Revised text
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
] Pdrive = 70[kmh]36(7919+073[N(kmh)]70[kmh]+003[N(kmh)sup2](70[kmh])sup2+1470[kg] 045[mssup2])0001
Annex IIIA Appendix 6 Paragraph 342
4
7066[kmh]36(7919+073[N(kmh)]7066[kmh]+003[N(kmh)sup2](7066[kmh])sup2+1470[kg]
0454[mssup2])0001
Argument
Inconsistent with ldquoACT WLTP after ISC V11final - cleanrdquo of December 2016
Argument Inconsistent with ldquoACT WLTP after ISC V11final - cleanrdquo of December 2016
Revised text
Backup
5
ACEA RDE lessons learned
A number of Lessons Learned issues were raised at the COM workshop on 1718th January 2017
bull Several of these have not been addressed by Package3
bull ACEArsquos review ndash facts amp questions ndash in following slides
Status 052017
6
ACEA Lessons Learned
Original text 6922008 Article 2 6
lsquoperiodically regenerating systemrsquo means catalytic converters particulate filters or other pollution control
devices that require a periodical regeneration process in less than 4 000 km of normal vehicle operation
Original text bdquoEU-WLTPldquo Annex XXI 381
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter
particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle
operation
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
7
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle operation
Revised text
ACEA Lessons Learned
Original text 6922008 Annex III 3134
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure
Original text bdquoEU-WLTPldquo Annex XXI Sub-Annex 6 -Appendix 1 12
During cycles where regeneration occurs emission standards need not apply If a periodic regeneration occurs
at least once per Type 1 test and has already occurred at least once during vehicle preparation it does not
require a special test procedure In this case this Appendix does not apply
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure If a periodically regenerating device has a
regeneration period in normal operation of greater than 4000 km it does not require a special test procedure
and the Ki factor may be set to 10 During cycles where regeneration occurs emission standards need not
apply If a periodic regeneration occurs at least once per Type 1 test and has already occurred at least once
during vehicle preparation it does not require a special test procedure In this case this Appendix does not
apply If a periodically regenerating device has a regeneration period in normal operation of greater than 4000
km it does not require a special test procedure and the Ki factor may be set to 10
Argument The current wording is somewhat illogical and frequently leads to misunderstandings The proposal
reflects the background to the requirements and maintains the concept that a system which regenerates
periodically (rather than continuously) is a periodically regenerating system but if the regeneration occurs every
cycle it will be considered in testing and requires no KI whereby a regeneration period of more than 4000 km
leads to negligible Ki factors which need not be determined
Revised text
ACEA Lessons Learned
Original text
Annex I Point 241 Figure I24
9
ArgumentRegarding PI vehicles PN requirements of RDE are not applied to mono fuel vehicles whose reference fuel is LPG NGBiomethane or Hydrogen Therefore they should be applied to bi-fuel vehicles and the vehicles should be tested with petrol only Regarding CI vehicles Type I test is conducted with B5B7 only Therefore RDE should be conducted with B5B7 only
Revised text
ACEA Lessons Learned
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Annex IIIA Paragraph 1216
10
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads
eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making
the necessary administrative arrangements If the respective PEMS test is not required by this Regulation
the manufacturer may charge a reasonable fee as set out in Article 7(1) of Regulation (EC) No 7152007
Annex IIIA Paragraph 24 - Renumbered to 25
11
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making the necessary administrative arrangements If the respective PEMS test is not required by this Regulation the manufacturer may charge a reasonable fee as set out comparable to the provision in Article 7(1) of Regulation (EC) No 7152007
Argument Article 7(1) is related only to repair and maintenance information
Revised text
ACEA Lessons Learned
New text (RDE 3)
3132 The manufacturer shall ensure that the information listed in point 31321 is made available on
a publicly accessible website without costs and without the need for the user to reveal his identity or sign
up The manufacturer shall keep the Commission and Type Approval Authorities informed on the location of
the website
31321 The website shall allow a wildcard search of the underlying database based on one or more of the
following
Make Type Variant Version Commercial name or Vehicle Identification Number as defined in the
Certificate of Conformity pursuant to Annex IX to this Regulation
The information described below shall be made available for all vehicles in a search
the results of the PEMS tests as set out in point 63 of Appendix 5 point 39 of Appendix 6 and point
4 of Appendix 7c for all vehicle emission types in the list described in point 54 of Appendix 7 For
NOVC-HEVs the results of the PEMS tests as set out in point 63 of Appendix 5 and if applicable
point 39 of Appendix 6 shall be reported For OVC-HEVs the results of the PEMS test as set out in
point 4 of Appendix 7c shall be reported
the Declared Maximum RDE Values as reported in point 482 of the Certificate of Conformity as
described in Annex IX of Directive 200746EC
Annex IIIA Paragraph 31321
12
31321 The website shall allow a wildcard search of the underlying database based on one or more of the following Make Type Variant Version Commercial name or Vehicle Identification Number Type Approval Number as defined in the Certificate of Conformity pursuant to Annex IX to this Regulation
ArgumentVIN does not have more information than Type Variant Version and Type approval number
Revised text
ACEA Lessons Learned
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test
family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described
in point 53 but with a warm engine
Annex IIIA Paragraph 45
13
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described in point 53 but with a warm engine with engine coolant temperature and engine oil temperature above 343 K
Argument Clarification
Revised text
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
Backup
5
ACEA RDE lessons learned
A number of Lessons Learned issues were raised at the COM workshop on 1718th January 2017
bull Several of these have not been addressed by Package3
bull ACEArsquos review ndash facts amp questions ndash in following slides
Status 052017
6
ACEA Lessons Learned
Original text 6922008 Article 2 6
lsquoperiodically regenerating systemrsquo means catalytic converters particulate filters or other pollution control
devices that require a periodical regeneration process in less than 4 000 km of normal vehicle operation
Original text bdquoEU-WLTPldquo Annex XXI 381
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter
particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle
operation
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
7
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle operation
Revised text
ACEA Lessons Learned
Original text 6922008 Annex III 3134
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure
Original text bdquoEU-WLTPldquo Annex XXI Sub-Annex 6 -Appendix 1 12
During cycles where regeneration occurs emission standards need not apply If a periodic regeneration occurs
at least once per Type 1 test and has already occurred at least once during vehicle preparation it does not
require a special test procedure In this case this Appendix does not apply
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure If a periodically regenerating device has a
regeneration period in normal operation of greater than 4000 km it does not require a special test procedure
and the Ki factor may be set to 10 During cycles where regeneration occurs emission standards need not
apply If a periodic regeneration occurs at least once per Type 1 test and has already occurred at least once
during vehicle preparation it does not require a special test procedure In this case this Appendix does not
apply If a periodically regenerating device has a regeneration period in normal operation of greater than 4000
km it does not require a special test procedure and the Ki factor may be set to 10
Argument The current wording is somewhat illogical and frequently leads to misunderstandings The proposal
reflects the background to the requirements and maintains the concept that a system which regenerates
periodically (rather than continuously) is a periodically regenerating system but if the regeneration occurs every
cycle it will be considered in testing and requires no KI whereby a regeneration period of more than 4000 km
leads to negligible Ki factors which need not be determined
Revised text
ACEA Lessons Learned
Original text
Annex I Point 241 Figure I24
9
ArgumentRegarding PI vehicles PN requirements of RDE are not applied to mono fuel vehicles whose reference fuel is LPG NGBiomethane or Hydrogen Therefore they should be applied to bi-fuel vehicles and the vehicles should be tested with petrol only Regarding CI vehicles Type I test is conducted with B5B7 only Therefore RDE should be conducted with B5B7 only
Revised text
ACEA Lessons Learned
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Annex IIIA Paragraph 1216
10
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads
eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making
the necessary administrative arrangements If the respective PEMS test is not required by this Regulation
the manufacturer may charge a reasonable fee as set out in Article 7(1) of Regulation (EC) No 7152007
Annex IIIA Paragraph 24 - Renumbered to 25
11
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making the necessary administrative arrangements If the respective PEMS test is not required by this Regulation the manufacturer may charge a reasonable fee as set out comparable to the provision in Article 7(1) of Regulation (EC) No 7152007
Argument Article 7(1) is related only to repair and maintenance information
Revised text
ACEA Lessons Learned
New text (RDE 3)
3132 The manufacturer shall ensure that the information listed in point 31321 is made available on
a publicly accessible website without costs and without the need for the user to reveal his identity or sign
up The manufacturer shall keep the Commission and Type Approval Authorities informed on the location of
the website
31321 The website shall allow a wildcard search of the underlying database based on one or more of the
following
Make Type Variant Version Commercial name or Vehicle Identification Number as defined in the
Certificate of Conformity pursuant to Annex IX to this Regulation
The information described below shall be made available for all vehicles in a search
the results of the PEMS tests as set out in point 63 of Appendix 5 point 39 of Appendix 6 and point
4 of Appendix 7c for all vehicle emission types in the list described in point 54 of Appendix 7 For
NOVC-HEVs the results of the PEMS tests as set out in point 63 of Appendix 5 and if applicable
point 39 of Appendix 6 shall be reported For OVC-HEVs the results of the PEMS test as set out in
point 4 of Appendix 7c shall be reported
the Declared Maximum RDE Values as reported in point 482 of the Certificate of Conformity as
described in Annex IX of Directive 200746EC
Annex IIIA Paragraph 31321
12
31321 The website shall allow a wildcard search of the underlying database based on one or more of the following Make Type Variant Version Commercial name or Vehicle Identification Number Type Approval Number as defined in the Certificate of Conformity pursuant to Annex IX to this Regulation
ArgumentVIN does not have more information than Type Variant Version and Type approval number
Revised text
ACEA Lessons Learned
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test
family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described
in point 53 but with a warm engine
Annex IIIA Paragraph 45
13
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described in point 53 but with a warm engine with engine coolant temperature and engine oil temperature above 343 K
Argument Clarification
Revised text
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA RDE lessons learned
A number of Lessons Learned issues were raised at the COM workshop on 1718th January 2017
bull Several of these have not been addressed by Package3
bull ACEArsquos review ndash facts amp questions ndash in following slides
Status 052017
6
ACEA Lessons Learned
Original text 6922008 Article 2 6
lsquoperiodically regenerating systemrsquo means catalytic converters particulate filters or other pollution control
devices that require a periodical regeneration process in less than 4 000 km of normal vehicle operation
Original text bdquoEU-WLTPldquo Annex XXI 381
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter
particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle
operation
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
7
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle operation
Revised text
ACEA Lessons Learned
Original text 6922008 Annex III 3134
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure
Original text bdquoEU-WLTPldquo Annex XXI Sub-Annex 6 -Appendix 1 12
During cycles where regeneration occurs emission standards need not apply If a periodic regeneration occurs
at least once per Type 1 test and has already occurred at least once during vehicle preparation it does not
require a special test procedure In this case this Appendix does not apply
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure If a periodically regenerating device has a
regeneration period in normal operation of greater than 4000 km it does not require a special test procedure
and the Ki factor may be set to 10 During cycles where regeneration occurs emission standards need not
apply If a periodic regeneration occurs at least once per Type 1 test and has already occurred at least once
during vehicle preparation it does not require a special test procedure In this case this Appendix does not
apply If a periodically regenerating device has a regeneration period in normal operation of greater than 4000
km it does not require a special test procedure and the Ki factor may be set to 10
Argument The current wording is somewhat illogical and frequently leads to misunderstandings The proposal
reflects the background to the requirements and maintains the concept that a system which regenerates
periodically (rather than continuously) is a periodically regenerating system but if the regeneration occurs every
cycle it will be considered in testing and requires no KI whereby a regeneration period of more than 4000 km
leads to negligible Ki factors which need not be determined
Revised text
ACEA Lessons Learned
Original text
Annex I Point 241 Figure I24
9
ArgumentRegarding PI vehicles PN requirements of RDE are not applied to mono fuel vehicles whose reference fuel is LPG NGBiomethane or Hydrogen Therefore they should be applied to bi-fuel vehicles and the vehicles should be tested with petrol only Regarding CI vehicles Type I test is conducted with B5B7 only Therefore RDE should be conducted with B5B7 only
Revised text
ACEA Lessons Learned
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Annex IIIA Paragraph 1216
10
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads
eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making
the necessary administrative arrangements If the respective PEMS test is not required by this Regulation
the manufacturer may charge a reasonable fee as set out in Article 7(1) of Regulation (EC) No 7152007
Annex IIIA Paragraph 24 - Renumbered to 25
11
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making the necessary administrative arrangements If the respective PEMS test is not required by this Regulation the manufacturer may charge a reasonable fee as set out comparable to the provision in Article 7(1) of Regulation (EC) No 7152007
Argument Article 7(1) is related only to repair and maintenance information
Revised text
ACEA Lessons Learned
New text (RDE 3)
3132 The manufacturer shall ensure that the information listed in point 31321 is made available on
a publicly accessible website without costs and without the need for the user to reveal his identity or sign
up The manufacturer shall keep the Commission and Type Approval Authorities informed on the location of
the website
31321 The website shall allow a wildcard search of the underlying database based on one or more of the
following
Make Type Variant Version Commercial name or Vehicle Identification Number as defined in the
Certificate of Conformity pursuant to Annex IX to this Regulation
The information described below shall be made available for all vehicles in a search
the results of the PEMS tests as set out in point 63 of Appendix 5 point 39 of Appendix 6 and point
4 of Appendix 7c for all vehicle emission types in the list described in point 54 of Appendix 7 For
NOVC-HEVs the results of the PEMS tests as set out in point 63 of Appendix 5 and if applicable
point 39 of Appendix 6 shall be reported For OVC-HEVs the results of the PEMS test as set out in
point 4 of Appendix 7c shall be reported
the Declared Maximum RDE Values as reported in point 482 of the Certificate of Conformity as
described in Annex IX of Directive 200746EC
Annex IIIA Paragraph 31321
12
31321 The website shall allow a wildcard search of the underlying database based on one or more of the following Make Type Variant Version Commercial name or Vehicle Identification Number Type Approval Number as defined in the Certificate of Conformity pursuant to Annex IX to this Regulation
ArgumentVIN does not have more information than Type Variant Version and Type approval number
Revised text
ACEA Lessons Learned
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test
family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described
in point 53 but with a warm engine
Annex IIIA Paragraph 45
13
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described in point 53 but with a warm engine with engine coolant temperature and engine oil temperature above 343 K
Argument Clarification
Revised text
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Original text 6922008 Article 2 6
lsquoperiodically regenerating systemrsquo means catalytic converters particulate filters or other pollution control
devices that require a periodical regeneration process in less than 4 000 km of normal vehicle operation
Original text bdquoEU-WLTPldquo Annex XXI 381
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter
particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle
operation
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
7
Periodically regenerating system means an exhaust emissions control device (eg catalytic converter particulate trap) that requires a periodical regeneration process in less than 4000 km of normal vehicle operation
Revised text
ACEA Lessons Learned
Original text 6922008 Annex III 3134
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure
Original text bdquoEU-WLTPldquo Annex XXI Sub-Annex 6 -Appendix 1 12
During cycles where regeneration occurs emission standards need not apply If a periodic regeneration occurs
at least once per Type 1 test and has already occurred at least once during vehicle preparation it does not
require a special test procedure In this case this Appendix does not apply
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure If a periodically regenerating device has a
regeneration period in normal operation of greater than 4000 km it does not require a special test procedure
and the Ki factor may be set to 10 During cycles where regeneration occurs emission standards need not
apply If a periodic regeneration occurs at least once per Type 1 test and has already occurred at least once
during vehicle preparation it does not require a special test procedure In this case this Appendix does not
apply If a periodically regenerating device has a regeneration period in normal operation of greater than 4000
km it does not require a special test procedure and the Ki factor may be set to 10
Argument The current wording is somewhat illogical and frequently leads to misunderstandings The proposal
reflects the background to the requirements and maintains the concept that a system which regenerates
periodically (rather than continuously) is a periodically regenerating system but if the regeneration occurs every
cycle it will be considered in testing and requires no KI whereby a regeneration period of more than 4000 km
leads to negligible Ki factors which need not be determined
Revised text
ACEA Lessons Learned
Original text
Annex I Point 241 Figure I24
9
ArgumentRegarding PI vehicles PN requirements of RDE are not applied to mono fuel vehicles whose reference fuel is LPG NGBiomethane or Hydrogen Therefore they should be applied to bi-fuel vehicles and the vehicles should be tested with petrol only Regarding CI vehicles Type I test is conducted with B5B7 only Therefore RDE should be conducted with B5B7 only
Revised text
ACEA Lessons Learned
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Annex IIIA Paragraph 1216
10
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads
eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making
the necessary administrative arrangements If the respective PEMS test is not required by this Regulation
the manufacturer may charge a reasonable fee as set out in Article 7(1) of Regulation (EC) No 7152007
Annex IIIA Paragraph 24 - Renumbered to 25
11
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making the necessary administrative arrangements If the respective PEMS test is not required by this Regulation the manufacturer may charge a reasonable fee as set out comparable to the provision in Article 7(1) of Regulation (EC) No 7152007
Argument Article 7(1) is related only to repair and maintenance information
Revised text
ACEA Lessons Learned
New text (RDE 3)
3132 The manufacturer shall ensure that the information listed in point 31321 is made available on
a publicly accessible website without costs and without the need for the user to reveal his identity or sign
up The manufacturer shall keep the Commission and Type Approval Authorities informed on the location of
the website
31321 The website shall allow a wildcard search of the underlying database based on one or more of the
following
Make Type Variant Version Commercial name or Vehicle Identification Number as defined in the
Certificate of Conformity pursuant to Annex IX to this Regulation
The information described below shall be made available for all vehicles in a search
the results of the PEMS tests as set out in point 63 of Appendix 5 point 39 of Appendix 6 and point
4 of Appendix 7c for all vehicle emission types in the list described in point 54 of Appendix 7 For
NOVC-HEVs the results of the PEMS tests as set out in point 63 of Appendix 5 and if applicable
point 39 of Appendix 6 shall be reported For OVC-HEVs the results of the PEMS test as set out in
point 4 of Appendix 7c shall be reported
the Declared Maximum RDE Values as reported in point 482 of the Certificate of Conformity as
described in Annex IX of Directive 200746EC
Annex IIIA Paragraph 31321
12
31321 The website shall allow a wildcard search of the underlying database based on one or more of the following Make Type Variant Version Commercial name or Vehicle Identification Number Type Approval Number as defined in the Certificate of Conformity pursuant to Annex IX to this Regulation
ArgumentVIN does not have more information than Type Variant Version and Type approval number
Revised text
ACEA Lessons Learned
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test
family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described
in point 53 but with a warm engine
Annex IIIA Paragraph 45
13
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described in point 53 but with a warm engine with engine coolant temperature and engine oil temperature above 343 K
Argument Clarification
Revised text
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Original text 6922008 Annex III 3134
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure
Original text bdquoEU-WLTPldquo Annex XXI Sub-Annex 6 -Appendix 1 12
During cycles where regeneration occurs emission standards need not apply If a periodic regeneration occurs
at least once per Type 1 test and has already occurred at least once during vehicle preparation it does not
require a special test procedure In this case this Appendix does not apply
6922008 Article 2(6) Annex III Para 3134 bdquoEU-WLTPldquoAnnex XXI Para 381 Annex XXI Sub-Annex 6 -Appendix 1 Para 12
For a periodically regenerating device during cycles where regeneration occurs emission standards can be
exceeded If a regeneration of a pollution control device occurs at least once per type 1 test and the device has
already regenerated at least once during vehicle preparation cycle it shall be considered as a continuously
regenerating system which does not require a special test procedure If a periodically regenerating device has a
regeneration period in normal operation of greater than 4000 km it does not require a special test procedure
and the Ki factor may be set to 10 During cycles where regeneration occurs emission standards need not
apply If a periodic regeneration occurs at least once per Type 1 test and has already occurred at least once
during vehicle preparation it does not require a special test procedure In this case this Appendix does not
apply If a periodically regenerating device has a regeneration period in normal operation of greater than 4000
km it does not require a special test procedure and the Ki factor may be set to 10
Argument The current wording is somewhat illogical and frequently leads to misunderstandings The proposal
reflects the background to the requirements and maintains the concept that a system which regenerates
periodically (rather than continuously) is a periodically regenerating system but if the regeneration occurs every
cycle it will be considered in testing and requires no KI whereby a regeneration period of more than 4000 km
leads to negligible Ki factors which need not be determined
Revised text
ACEA Lessons Learned
Original text
Annex I Point 241 Figure I24
9
ArgumentRegarding PI vehicles PN requirements of RDE are not applied to mono fuel vehicles whose reference fuel is LPG NGBiomethane or Hydrogen Therefore they should be applied to bi-fuel vehicles and the vehicles should be tested with petrol only Regarding CI vehicles Type I test is conducted with B5B7 only Therefore RDE should be conducted with B5B7 only
Revised text
ACEA Lessons Learned
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Annex IIIA Paragraph 1216
10
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads
eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making
the necessary administrative arrangements If the respective PEMS test is not required by this Regulation
the manufacturer may charge a reasonable fee as set out in Article 7(1) of Regulation (EC) No 7152007
Annex IIIA Paragraph 24 - Renumbered to 25
11
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making the necessary administrative arrangements If the respective PEMS test is not required by this Regulation the manufacturer may charge a reasonable fee as set out comparable to the provision in Article 7(1) of Regulation (EC) No 7152007
Argument Article 7(1) is related only to repair and maintenance information
Revised text
ACEA Lessons Learned
New text (RDE 3)
3132 The manufacturer shall ensure that the information listed in point 31321 is made available on
a publicly accessible website without costs and without the need for the user to reveal his identity or sign
up The manufacturer shall keep the Commission and Type Approval Authorities informed on the location of
the website
31321 The website shall allow a wildcard search of the underlying database based on one or more of the
following
Make Type Variant Version Commercial name or Vehicle Identification Number as defined in the
Certificate of Conformity pursuant to Annex IX to this Regulation
The information described below shall be made available for all vehicles in a search
the results of the PEMS tests as set out in point 63 of Appendix 5 point 39 of Appendix 6 and point
4 of Appendix 7c for all vehicle emission types in the list described in point 54 of Appendix 7 For
NOVC-HEVs the results of the PEMS tests as set out in point 63 of Appendix 5 and if applicable
point 39 of Appendix 6 shall be reported For OVC-HEVs the results of the PEMS test as set out in
point 4 of Appendix 7c shall be reported
the Declared Maximum RDE Values as reported in point 482 of the Certificate of Conformity as
described in Annex IX of Directive 200746EC
Annex IIIA Paragraph 31321
12
31321 The website shall allow a wildcard search of the underlying database based on one or more of the following Make Type Variant Version Commercial name or Vehicle Identification Number Type Approval Number as defined in the Certificate of Conformity pursuant to Annex IX to this Regulation
ArgumentVIN does not have more information than Type Variant Version and Type approval number
Revised text
ACEA Lessons Learned
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test
family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described
in point 53 but with a warm engine
Annex IIIA Paragraph 45
13
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described in point 53 but with a warm engine with engine coolant temperature and engine oil temperature above 343 K
Argument Clarification
Revised text
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Original text
Annex I Point 241 Figure I24
9
ArgumentRegarding PI vehicles PN requirements of RDE are not applied to mono fuel vehicles whose reference fuel is LPG NGBiomethane or Hydrogen Therefore they should be applied to bi-fuel vehicles and the vehicles should be tested with petrol only Regarding CI vehicles Type I test is conducted with B5B7 only Therefore RDE should be conducted with B5B7 only
Revised text
ACEA Lessons Learned
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Annex IIIA Paragraph 1216
10
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads
eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making
the necessary administrative arrangements If the respective PEMS test is not required by this Regulation
the manufacturer may charge a reasonable fee as set out in Article 7(1) of Regulation (EC) No 7152007
Annex IIIA Paragraph 24 - Renumbered to 25
11
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making the necessary administrative arrangements If the respective PEMS test is not required by this Regulation the manufacturer may charge a reasonable fee as set out comparable to the provision in Article 7(1) of Regulation (EC) No 7152007
Argument Article 7(1) is related only to repair and maintenance information
Revised text
ACEA Lessons Learned
New text (RDE 3)
3132 The manufacturer shall ensure that the information listed in point 31321 is made available on
a publicly accessible website without costs and without the need for the user to reveal his identity or sign
up The manufacturer shall keep the Commission and Type Approval Authorities informed on the location of
the website
31321 The website shall allow a wildcard search of the underlying database based on one or more of the
following
Make Type Variant Version Commercial name or Vehicle Identification Number as defined in the
Certificate of Conformity pursuant to Annex IX to this Regulation
The information described below shall be made available for all vehicles in a search
the results of the PEMS tests as set out in point 63 of Appendix 5 point 39 of Appendix 6 and point
4 of Appendix 7c for all vehicle emission types in the list described in point 54 of Appendix 7 For
NOVC-HEVs the results of the PEMS tests as set out in point 63 of Appendix 5 and if applicable
point 39 of Appendix 6 shall be reported For OVC-HEVs the results of the PEMS test as set out in
point 4 of Appendix 7c shall be reported
the Declared Maximum RDE Values as reported in point 482 of the Certificate of Conformity as
described in Annex IX of Directive 200746EC
Annex IIIA Paragraph 31321
12
31321 The website shall allow a wildcard search of the underlying database based on one or more of the following Make Type Variant Version Commercial name or Vehicle Identification Number Type Approval Number as defined in the Certificate of Conformity pursuant to Annex IX to this Regulation
ArgumentVIN does not have more information than Type Variant Version and Type approval number
Revised text
ACEA Lessons Learned
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test
family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described
in point 53 but with a warm engine
Annex IIIA Paragraph 45
13
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described in point 53 but with a warm engine with engine coolant temperature and engine oil temperature above 343 K
Argument Clarification
Revised text
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Annex IIIA Paragraph 1216
10
ldquoNoiserdquo means two times the root mean square of ten standard deviations each calculated from the zero
responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads
eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making
the necessary administrative arrangements If the respective PEMS test is not required by this Regulation
the manufacturer may charge a reasonable fee as set out in Article 7(1) of Regulation (EC) No 7152007
Annex IIIA Paragraph 24 - Renumbered to 25
11
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making the necessary administrative arrangements If the respective PEMS test is not required by this Regulation the manufacturer may charge a reasonable fee as set out comparable to the provision in Article 7(1) of Regulation (EC) No 7152007
Argument Article 7(1) is related only to repair and maintenance information
Revised text
ACEA Lessons Learned
New text (RDE 3)
3132 The manufacturer shall ensure that the information listed in point 31321 is made available on
a publicly accessible website without costs and without the need for the user to reveal his identity or sign
up The manufacturer shall keep the Commission and Type Approval Authorities informed on the location of
the website
31321 The website shall allow a wildcard search of the underlying database based on one or more of the
following
Make Type Variant Version Commercial name or Vehicle Identification Number as defined in the
Certificate of Conformity pursuant to Annex IX to this Regulation
The information described below shall be made available for all vehicles in a search
the results of the PEMS tests as set out in point 63 of Appendix 5 point 39 of Appendix 6 and point
4 of Appendix 7c for all vehicle emission types in the list described in point 54 of Appendix 7 For
NOVC-HEVs the results of the PEMS tests as set out in point 63 of Appendix 5 and if applicable
point 39 of Appendix 6 shall be reported For OVC-HEVs the results of the PEMS test as set out in
point 4 of Appendix 7c shall be reported
the Declared Maximum RDE Values as reported in point 482 of the Certificate of Conformity as
described in Annex IX of Directive 200746EC
Annex IIIA Paragraph 31321
12
31321 The website shall allow a wildcard search of the underlying database based on one or more of the following Make Type Variant Version Commercial name or Vehicle Identification Number Type Approval Number as defined in the Certificate of Conformity pursuant to Annex IX to this Regulation
ArgumentVIN does not have more information than Type Variant Version and Type approval number
Revised text
ACEA Lessons Learned
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test
family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described
in point 53 but with a warm engine
Annex IIIA Paragraph 45
13
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described in point 53 but with a warm engine with engine coolant temperature and engine oil temperature above 343 K
Argument Clarification
Revised text
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads
eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making
the necessary administrative arrangements If the respective PEMS test is not required by this Regulation
the manufacturer may charge a reasonable fee as set out in Article 7(1) of Regulation (EC) No 7152007
Annex IIIA Paragraph 24 - Renumbered to 25
11
Manufacturers shall ensure that vehicles can be tested with PEMS by an independent party on public roads eg by making available suitable adapters for exhaust pipes granting access to ECU signals and making the necessary administrative arrangements If the respective PEMS test is not required by this Regulation the manufacturer may charge a reasonable fee as set out comparable to the provision in Article 7(1) of Regulation (EC) No 7152007
Argument Article 7(1) is related only to repair and maintenance information
Revised text
ACEA Lessons Learned
New text (RDE 3)
3132 The manufacturer shall ensure that the information listed in point 31321 is made available on
a publicly accessible website without costs and without the need for the user to reveal his identity or sign
up The manufacturer shall keep the Commission and Type Approval Authorities informed on the location of
the website
31321 The website shall allow a wildcard search of the underlying database based on one or more of the
following
Make Type Variant Version Commercial name or Vehicle Identification Number as defined in the
Certificate of Conformity pursuant to Annex IX to this Regulation
The information described below shall be made available for all vehicles in a search
the results of the PEMS tests as set out in point 63 of Appendix 5 point 39 of Appendix 6 and point
4 of Appendix 7c for all vehicle emission types in the list described in point 54 of Appendix 7 For
NOVC-HEVs the results of the PEMS tests as set out in point 63 of Appendix 5 and if applicable
point 39 of Appendix 6 shall be reported For OVC-HEVs the results of the PEMS test as set out in
point 4 of Appendix 7c shall be reported
the Declared Maximum RDE Values as reported in point 482 of the Certificate of Conformity as
described in Annex IX of Directive 200746EC
Annex IIIA Paragraph 31321
12
31321 The website shall allow a wildcard search of the underlying database based on one or more of the following Make Type Variant Version Commercial name or Vehicle Identification Number Type Approval Number as defined in the Certificate of Conformity pursuant to Annex IX to this Regulation
ArgumentVIN does not have more information than Type Variant Version and Type approval number
Revised text
ACEA Lessons Learned
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test
family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described
in point 53 but with a warm engine
Annex IIIA Paragraph 45
13
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described in point 53 but with a warm engine with engine coolant temperature and engine oil temperature above 343 K
Argument Clarification
Revised text
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
New text (RDE 3)
3132 The manufacturer shall ensure that the information listed in point 31321 is made available on
a publicly accessible website without costs and without the need for the user to reveal his identity or sign
up The manufacturer shall keep the Commission and Type Approval Authorities informed on the location of
the website
31321 The website shall allow a wildcard search of the underlying database based on one or more of the
following
Make Type Variant Version Commercial name or Vehicle Identification Number as defined in the
Certificate of Conformity pursuant to Annex IX to this Regulation
The information described below shall be made available for all vehicles in a search
the results of the PEMS tests as set out in point 63 of Appendix 5 point 39 of Appendix 6 and point
4 of Appendix 7c for all vehicle emission types in the list described in point 54 of Appendix 7 For
NOVC-HEVs the results of the PEMS tests as set out in point 63 of Appendix 5 and if applicable
point 39 of Appendix 6 shall be reported For OVC-HEVs the results of the PEMS test as set out in
point 4 of Appendix 7c shall be reported
the Declared Maximum RDE Values as reported in point 482 of the Certificate of Conformity as
described in Annex IX of Directive 200746EC
Annex IIIA Paragraph 31321
12
31321 The website shall allow a wildcard search of the underlying database based on one or more of the following Make Type Variant Version Commercial name or Vehicle Identification Number Type Approval Number as defined in the Certificate of Conformity pursuant to Annex IX to this Regulation
ArgumentVIN does not have more information than Type Variant Version and Type approval number
Revised text
ACEA Lessons Learned
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test
family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described
in point 53 but with a warm engine
Annex IIIA Paragraph 45
13
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described in point 53 but with a warm engine with engine coolant temperature and engine oil temperature above 343 K
Argument Clarification
Revised text
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test
family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described
in point 53 but with a warm engine
Annex IIIA Paragraph 45
13
In order to also assess emissions during trips in hot start a certain number of vehicles per PEMS test family specified in point 427 in Appendix 7 shall be tested without conditioning the vehicle as described in point 53 but with a warm engine with engine coolant temperature and engine oil temperature above 343 K
Argument Clarification
Revised text
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods
described in Appendix 7a to this Annex
Annex IIIA Paragraph 541
14
The overall excess or insufficiency of driving dynamics during the trip shall be checked using the methods described in Appendix 7a and 7b to this Annex
Argument Appendix 7b to be mentioned as well
Revised text
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
If the trip results are valid following the verifications in accordance with point 541 the methods for
verifying the normality of the test conditions as laid down in Appendices 5 6 7a and 7b to this Annex shall
be applied For OVC-HEVs only the validity of a trip and the normality of test conditions are verified in
accordance with Appendix 7c while Appendices 5 and 6 do not apply
Annex IIIA Paragraph 542
15
If the trip results are valid following the verifications in accordance with point 541 the methods for verifying
the normality of the test conditions as laid down in Appendices 5 and 6 7a and 7b to this Annex shall be
applied Compliance of the software tool with the provisions laid down in Appendix 5 or 6 shall either be
certified by the tool provider or testified by the type approval authority For OVC-HEVs only the validity of a trip
and the normality of test conditions are verified in accordance with Appendix 7c while Appendices 5 and 6 do
not apply
Argument Correction The software provider should prove compliance with the methods laid down in Appendix 5 or 6 by an
approval authority certificate Compliance of non-certified software tools with the provisions of Appendix 5 or 6 should be testified by the type approval authority conducting or supervising the RDE tests
Revised text
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Auxiliary systems
The air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their
possible use by a consumer at real driving on the road
Annex IIIA Paragraph 551
16
Auxiliary systemsThe air conditioning system or other auxiliary devices shall be operated in a way which corresponds to their possible typically intended use by a consumer at real driving on the roadMisuse ndash useful wording necessaryThe Use of Auxiliary systems has to be documented
Argument ldquopossiblerdquo would include also an intentionally unreasonable use of such a device Misuse has to be defined Better understanding what happened during the RDE-Trip
Revised text
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Annex IIIA New Paragraph 553
17
Additional modifications on top of the PEMS that changes the aerodynamic is not permitted
ArgumentTo avoid drag variations caused by significant modifications
New text
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Annex IIIA New Paragraph 554
18
It should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns If there are reasonable grounds to challenge a result than verification of biased driving may be based in expert judgements through cross-correlation on several signals which may include exhaust flow rate exhaust temperature CO2 O2 etc in combination with vehicle speed acceleration and GPS data and potentially further vehicle data parameters like engine speed gear accelerator pedal position etc
Argument While it is important that RDE testing includes all valid driving conditions within the specified boundary
conditions it should be avoided that the tested vehicles are driven in a biased manner ie with the intention to generate a passed or failed test not by virtue of the technical performance of the vehicle but due to extreme driving patterns
New text
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
The idling immediately after the first ignition of the combustion engine shall be kept to the minimum
possible and it shall not exceed 15 s
Annex IIIA Paragraph 76
19
At the beginning of the trip the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s vehicle stopped
Argument For OVC-HEV the first ignition of combustion engine may occur after several km of trip As the vehicle is still
moved by electric way there is no need to limit the idle period
Revised text
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Samples of fuel lubricant and reagent (if applicable) shall be taken and kept for at least 1 year
Annex IIIA Paragraph 82
20
In the case of a PEMS test with a failed result samples of fuel lubricant and reagent (if applicable) shall be
taken and kept for at least 1 year
After the analysis has been made and stored the samples are not necessary anymore
Argument specifications of the fuel oil and reagent are very important
Revised text
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant
frequency of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters
are obtained these should be made available at a substantially higher frequency than the parameters
recorded by PEMS The PEMS analysers flow-measuring instruments and sensors shall comply with the
requirements laid down in Appendices 2 and 3 of this Annex
Annex IIIA Appendix 1 Paragraph 32
21
Test parameters as specified in Table 1 of this Appendix shall be measured recorded at a constant frequency
of 10 Hz or higher and reported according to the requirements of Appendix 8 If ECU parameters are
obtained available these should be made available requested at a substantially higher the same frequency
than as the parameters recorded by PEMS The PEMS analysers flow-measuring instruments and sensors
shall comply with the requirements laid down in Appendices 2 and 3 of this Annex
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data Table 1 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
The available data rate depends on the type and amount of requested data and on the number of answering control units A data rate ldquosubstantially higherldquo than 1Hz may not be possible
Revised text
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
New text (RDE 3)
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant
frequency of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Annex IIIA Appendix 1 Paragraph 46
22
The zero level of the analyser shall be recorded by sampling HEPA filtered ambient air at an appropriate
sampling point usually at the inlet of the sampling line The signal shall be recorded at a constant frequency
of at least 10 Hz averaged over a period of 2 minutes the final concentration shall be within the
manufacturerrsquos specifications but shall not exceed 5000 particles per cubic-centimetre
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
The calibrated range of the analysers shall account at least for 90 of the concentration values obtained
from 99 of the measurements of the valid parts of the emissions test It is permissible that 1 of the
total number of measurements used for evaluation exceeds the calibrated range of the analysers by up to a
factor of two If these requirements are not met the test shall be voided
Annex IIIA Appendix 1 Paragraph 63
23
The used span gas concentration of the analysers as calibrated according to Appendix 1 paragraph 45 of
this Annex shall cover at least 90 of the concentration values obtained from 99 of the measurements of
the valid parts of the emissions test It is permissible that 1 of the total number of measurements used for
evaluation exceeds the used span gas by up to a factor of two If these requirements are not met the test
shall be voided
Argument Clarification
Revised text
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Annex IIIA Appendix 2 Paragraph 342
24
(f) The values under evaluation and if needed the reference values shall be recorded at a constant
frequency of at least 10 Hz over a period of 30 seconds
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with
an interval of 30 seconds in which the analyser is exposed to an appropriate span gas Before each
sampling period and before each span period sufficient time shall be given to purge the analyser and the
sampling lines
Annex IIIA Appendix 2 Paragraph 424
25
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 of full scale Each of the 10 measurement periods shall be interspersed with an interval
of 30 seconds in which the analyser is exposed to an appropriate span gas Before each sampling period and
before each span period sufficient time shall be given to purge the analyser and the sampling lines
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30
seconds shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement
periods shall be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum
calibrated flow
Annex IIIA Appendix 2 Paragraph 725
26
The noise defined as two times the root mean square of ten standard deviations each calculated from the
zero responses measured at a constant recording frequency of at least 10 Hz during a period of 30 seconds
shall not exceed 2 per cent of the maximum calibrated flow value Each of the 10 measurement periods shall
be interspersed with an interval of 30 seconds in which the EFM is exposed to the maximum calibrated flow
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Annex IIIA Appendix 3 Paragraph 42
27
(c) At a constant frequency of at least 10 Hz the signal under validation and the reference signal shall be
correlated using the best-fit equation having the form
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
New text (RDE 3)
COLD START
Cold start is the period from the first start of the combustion engine until the point when the combustion
engine has run cumulatively for 5 min If the coolant temperature is determined the cold start period ends
once the coolant has reached 343 K (70 degC) for the first time but no later than the point at which the
combustion engine has run cumulatively for 5 min after initial engine start
Annex IIIA Appendix 3 Paragraph 42
28
COLD START
For RDE purposes only Cold start is the period from the first start of the combustion engine until the point
when the combustion engine has run cumulatively for 5 min If the coolant temperature is determined the
cold start period ends once the coolant has reached 343 K (70 degC) for the first time but no later than the
point at which the combustion engine has run cumulatively for 5 min after initial engine start
Argument This cold start definition is only valid for RDE
Revised text
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
42 CO 2 characteristic curve reference points The reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle) MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm] 422 Point P2
423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle) MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm] 424 Point P3
425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle) MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
ANNEX IIIa Appendix 5 Paragraph 42
29
42 CO 2 characteristic curve reference pointsThe reference points P1 P2 and P3 required to define the curve shall be established as follows 421 Point P1
Vehicles of categories M1 and N1vP1 = 19 kmh (average speed of the Low Speed phase of the WLTP cycle)Vehicles of categories M2 and N2 vP1 = [tbd]MCO 2dP 1 = Vehicle CO2 emissions over the Low Speed phase of the WLTP cycle times 12 [gkm]422 Point P2
Vehicles of categories M1 and N1423 vP2 = 566 kmh (average speed of the High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP2 = [tbd]MCO 2dP 2 = Vehicle CO2 emissions over the High Speed phase of the WLTP cycle times 11 [gkm]4243 Point P3
Vehicles of categories M1 and N1425 vP3 = 923kmh (average speed of the Extra High Speed phase of the WLTP cycle)Vehicles of categories M2 and N2vP3 = [tbd]MCO 2dP 3 = Vehicle CO 2 emissions over the Extra High Speed phase of the WLTP cycle times 105 [gkm]
Revised text
ArgumentThe factors of 12 11 and 105 obviously have been derived from NEDC tests Experience shows that these factors are not necessary anymore for WLTP tests
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
4 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45
kmh and smaller than 80 kmh
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to
80 kmh and smaller than 145 kmh
ANNEX IIIa Appendix 5 Paragraph 44
30
] kmh
44 Urban rural and motorway windows
441 Urban windows are characterised by average vehicle ground speeds vj smaller than 45 kmh for vehicles of categories M1 and N1 resp smaller than [tbd] kmh for vehicles of categories M2 and N2
442 Rural windows are characterised by average vehicle ground speeds vj greater than or equal to 45 kmh and smaller than 80 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
443 Motorway windows are characterised by average vehicle ground speeds vj greater than or equal to 80 kmh and smaller than 145 kmh for vehicles of categories M1 and N1 resp greater than or equal to [tbd] kmh and smaller than [tbd] kmh for vehicles of categories M2 and N2
Argument The calculation has to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by JRC or TU Graz
Revised text
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
i) Time step for instantaneous measurements minimum resolution 1Hz
Annex IIIA Appendix 6 Paragraph 2 Symbols parameters ampunits
31
i) Time step for instantaneous measurements minimum resolution 1Hz
Argument ACEA recommends to use a fixed frequency of 1 Hz in order to minimize interference with the provisions of
the other Appendices (particularly Appendix 6) and to facilitate post-processing of the data
Revised text
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
1 INTRODUCTION
Due to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type
with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this
Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types may be
put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of
point 3 which shall be validated according to the requirements of point 4
Annex IIIA Appendix 7 Paragraph 1
32
1 INTRODUCTIONDue to their particular characteristics PEMS tests are not required to be performed for each ldquovehicle type with regard to emissions and vehicle repair and maintenance informationrdquo as defined in Article 2(1) of this Regulation which is called in the following ldquovehicle emission typerdquo Several vehicle emission types with different declared maximum RDE values according to Part I of Annex IX to Directive 200746EC may be put together by the vehicle manufacturer to form a ldquoPEMS test familyrdquo according to the requirements of point 3 which shall be validated according to the requirements of point 4
Argument Clarification
Revised text
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
hellip
() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and
cold conditions
Annex IIIA Appendix 7 Paragraph 428
33
hellip() when there is only one vehicle emission type in a PEMS test family it shall be tested in both hot and orcold condition chosen by the Type Approval Authority
Argument This can make vehicles comply with RDE requirements in both hot and cold conditions and can also reduce
the workload
Revised text
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a
given PEMS test family on the basis of emission type approval numbers For each emission type all
corresponding combinations of vehicle type approval numbers types variants and versions as defined in
sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Annex IIIA Appendix 7 Paragraph 53
34
The authority and the vehicle manufacturer shall maintain a list of vehicle emission types being part of a given PEMS test family on the basis of emission type approval numbers For each emission type all corresponding combinations of vehicle type approval numbers types variants and versions as defined in sections 010 and 02 of the vehicles EC certificate of conformity shall be provided as well
Argument Not possible to provide all the VIN
Revised text
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Data pre-processing
hellip
The correct speed trace builds the basis for further calculations and binning as described in paragraph
812
Annex IIIA Appendix 7a Paragraph 811 Renumbered to 31
35
Data pre-processing hellip The correct speed trace builds the basis for further calculations and binning as described in paragraph 812
312 and 313
Argument Paragraph 812 renumbered to 312 Calculations are described in paragraph 312 binning is described in paragraph 313
Revised text
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
All datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
ANNEX IIIa Appendix 7a Paragraph 813 Renumbered to 31
36
Binning of the results
After the calculation of ai and (v a)i the values vi di ai and (v a)i shall be ranked in ascending order of the vehicle speed
For vehicles of categories M1 and N1 as defined in Annex II to Directive 70156EEC Aall datasets with vi le 60 kmh belong to the lsquourbanrsquo speed bin all datasets with 60 kmh lt vi le 90 kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt 90 kmh belong to the lsquomotorwayrsquo speed bin
For vehicles of categories M2 and N2 as defined in Annex II to Directive 70156EEC all datasets with vi le [tbd] kmh belong to the lsquourbanrsquo speed bin all datasets with [tbd] kmh lt vi le [tbd] kmh belong to the lsquoruralrsquo speed bin and all datasets with vi gt [tbd] kmh belong to the lsquomotorwayrsquo speed bin
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 150 in each speed bin
ANNEX IIIa Appendix 7a Paragraph 31
37
Binning of the results hellip The number of datasets with acceleration values shall be bigger or equal to 100 in each speed bin
Argument Reducing this number makes driving with Cruise Control on motorway possible
Revised text
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
+ve accel counts
Appendix 7a 313 specifies that there need to be gt150 +ve accel counts for
each of the 3 speed bins
We have been finding that typical trips have less counts for Motorway than for
Rural than for Urban just due to the nature of typical real world driving
And have been experiencing difficulty in achieving gt150 counts for Motorway
driving on a number of trips
So having to repeat tests with specific focus on driving more transiently than
the driver would normally do in order to meet this criteria
This has been experienced both with JLR drivers and VCA drivers
Perhaps this is worse in the UK with our 70 mph motorway speed limit as
therefore less delta between 90 kph and 113 kph within which to exercise +ve
acceleration
ACEA did discuss this with Dr Heinz Steven during the 0809Sep workshop in
Brussels and he mentioned that his original proposal was for a minimum
criteria of 100 counts (in order to be able to determine a 95ile value)
And checking with our Certification department confirmed that all of our trips
have achieved gt100 counts of +ve accel during Motorway driving - just falling
short of 150
Therefore we would like to propose that the criteria for the Motorway
speed bin is reduced to a minimum of 100 counts
ACEA Lessons Learned
Open Topics
38
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
VERIFICATION OF TRIP VALIDITY 411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh and RPAk lt 0025 is fulfilled the trip is invalid
ANNEX IIIa Appendix 7a Paragraph 31
39
411 Verification of vapos_[95] per speed bin (with v in [kmh]) If vk le 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (0136 vk + 1444) is fulfilled the trip is invalid If vkgt 746 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and (v apos)k [95] gt (00742 vk + 18966) is fulfilled the trip is invalid 412 Verification of RPA per speed bin If vk le 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt (- 00016 vk + 01755) is fulfilled the trip is invalid If vkgt 9405 kmh (M1N1 vehicles) resp vk le [tbd] kmh (M2N2 vehicles) and RPAk lt 0025 is fulfilled the trip is invalid
Argument The calculation needs to consider the splitting of the speed requirements in M1 N1 and M2 N2 vehicles (see
ANNEX IIIa paragraph 63-65) According to that the speed values have to be amended Reasonable values should be evaluated by CLEAR tool experts JRC or TU Graz
Revised text
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Percentage shall indicate the deviation from the gross vehicle weight
Annex IIIA Appendix 8 Table 1 Footnote 2
40
Percentage shall indicate the deviation from the gross vehicle weight according to Paragraph 512 of Annex IIIA
Argument Clarification
Revised text
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned
Original text (3rd column) ECU (appears in several lines of the table)
Annex IIIA Appendix 8 Table 2
41
Revised text(3rd column) ECU (5)
Additional footnote under Table 2 (5) if available
Argument Table 2 contains several values the data source of which is marked as ldquoECUrdquo However the transmission of
most of these values is not (or only optional) requested by the OBD regulation Thus it cannot be anticipated that these values are available from the ECU
Revised text
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
Uncertainties
42
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned - Uncertainties
ANNEX IIIPart I of Annex IX to Directive 200746EC is amended as follows
bull [abcd] A new point 482 is introduced after point 481 in the side 2 of the Certificate of Conformity (CoC) of [M1M2N1N2] vehicles as follows
bull 482 Declared maximum RDE values (if applicable)bull Complete RDE trip NOx helliphellip Particles (number) helliphellipbull Urban RDE trip NOx helliphellip Particles (number) helliphellip
In case the limit is 1 + margin and if the manufacturer wants to declare 80 mgkm should he declarebull 80 mgkm bull 80 mgkm + margin 120 mgkm (ie 80 + 05 margin = 120)
Annexes to the COM RDE Regulation (TCMV 20 Dec 2016)
43
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44
ACEA Lessons Learned - Uncertainties
bull Confused Road Load Model situation eg Many places in RDE regs use Reg83 RLM
PEMS validation procedure - Appendix 3 Section 322 Power Binning de-normalisation - Appendix 6 Section 341
But other places use GTR15 Moving Averaging Windowing CO2 characteristic curve generation - Appendix 5 Section
41 Power Binning VeLine defnition - Appendix 6 Section 4
However where GTR15 used theres no definition of what RLM to use - TEL TEH value for actual vehicle being RDE tested
It would be better to use only GTR15 and delete the requirement in Appendix 8 which require OEMs to submit Reg83 RL data
Annex IIIA Appendix 3 Section 322 Appendix 6 Section 341VSAppendix 5 Section 41
44