SiCo ACEA position RESULT slides proposal

Verification measures for CO2 HDV Commission's proposal Note on the conformity of production and ex-post verification provision in the procedures for the certification of the Co2 emissions form heavy duty vehicles, 14 March 2016 Commissions proposal; multi-level verification Certification testing and approval, following principles of 200746 Component + Process for CO2/FC determination COP verification, following principles of 2007/46 Component + Process for CO2/FC determination Ex-post verification of customer vehicles, in production - New procedure Vehicle test comparing tested values with simulated values Analysis of discrepancy to identify the root cause of a discrepancy Independent data verification – New procedure? (re-calculation, vehicle tests?) The purpose and added value is not clear Periodic VECTO software and procedure verification – Provision in regulation? Software and procedure verification by Commission ACEA asks for further clarification/evaluation of these verification procedures

Each point represents a SiCo test point, all OEMs represented experiences of stationary testing All OEMs have performed stationary tests on chassi-dyno or road and achieved good VECTO results. Product variations may somewhat increase the error. Harmonizing test conditions will decrease the error. Achievable accuracy VECTO/Measurement: ±5% Each point represents a SiCo test point, all OEMs represented

Chassis DYNo and/or test track? ACEA position: Have both options: stationary chassis dyno test and stationary road test OEM chooses which method to be used based on: Specific vehicle type to be tested Availability of test facilities Technical Authority chooses the vehicle to be tested and the load points.

experiences of Transient testing Transient testing on the road is not repeatable in terms of rpm, torque and auxiliary load. Repeatability of FC is in the order of ±7 %. Achievable accuracy VECTO/Measurement: ±7+5 ≥ 12 % Fuel consumption

experiences of Transient testing VECTO correlation is always worse in transient testing than in stationary testing due to: dynamic effects varying ambient conditions VECTO simplifications In some tests VECTO shows poor repeatability with transient SiCo data (rpm, torque, and gear). The reasons are under investigation. Regulatory transient testing requires a simulation model that takes account for dynamic effects and ambient conditions.

Reduce customer consequences Delivery delay is estimated on about 4 weeks for chassis dyno test Run in is necessary and leads to used vehicle with 8000 km’s run in Legal method has to be found to claim a customer vehicle Methods that give pre-warning to the OEM are not envisaged to be credible like: Build specific vehicle for SiCo test and sell it later as used vehicle TAA chooses vehicle type, OEM arranges with a costumer used vehicle arrangement Possible solution without pre-warning: TAA randomly selects a customer’s vehicle with maximum mileage of x km and make evident that it is an act of the authority to retain the vehicle of a customer

NUMBER of sico vehicles SiCo is an EX Post verification of the complete procedure for generating CO2 values for HDV. The authorities have to define the type and number of test vehicles needed for this purpose. The choice and number of vehicles can also be triggered by exceptional and unexpected CO2 values. For above objectives there is no reason to have each OEM testing a vehicle of each vehicle class yearly. It can efficiently be achieved if all vehicles chosen for SiCo tests are distributed over the OEM’s together to cover all classes over a given time span. Criteria for the type of vehicles to be selected and the yearly number of test vehicles: Contribution of the vehicle type to CO2 emission Production volume of OEM Exceptional and unexpected low CO2 values of a vehicle type / OEM

General remarks/ attention points CO2 will be regulated in the type approval framework with detailed CoP provisions (including component retesting) and process certification. The proposed full vehicle test is only testing the drive train (not tyres, air drag, driver assistance systems or auxiliaries) with lower accuracy than CoP component tests. Extensive SiCo testing will shift focus away from the relevant duty cycles, thus undermining the regulatory approach. The responsibility for the SiCo test most logically is to be attributed to the TA that is responsible for the conformity of the declaration process at the specific OEM. An effort is still needed to detail the test procedure and to write the technical annex, ACEA is willing to support this activity in a DG Grow expert group.