Heavy Duty Vehicle Requirements in EVS-GTR for HFCV-GTR Discussions TMNA

Summary of Scope of EVS-GTR Both LDV and HDV fall within the scope of EVS-GTR LDV requirements defined in EVS-GTR Exemptions for low mass, low-speed vehicles Low mass, high-speed vehicles are still covered under EVS-GTR HDV tests and requirements to be defined by separate task force at a later time Did not want slow down development of EVS-GTR Propose alterations and exemptions when appropriate Keep EVS-GTR more “user friendly” HDV and LDV may have different technology solutions (e.g., charging technology: HDV to minimize human involvement) Separate requirements for LDV allows for future revisions when technology is more evolved Each CP can decide to adopt HDV regulation HDV testing should be component-based and not vehicle-based HDV/incomplete HDVs (chassis)have different applications and rebuilds over their lifetimes Custom HDVs are common depending on application and customer HDV manufacturers are more “integrators” and may not make all components (e.g., body) . Thus, conditions and limitations must be considered in detail for HDV especially for incomplete vehicle compliance. If HDV component test not feasible, then must limit set of representative vehicle designs to test for compliance of the entire range. Must ensure LDV requirements do not become technology limiting for HDVs. Especially for criteria with high potential of becoming market normative

APPENDIX GRSP-61-07

GRSP-61-07

GRSP-61-07

GRSP-61-07

EVS-GTR Scope Comment Section Category 1 and Category 2 with max speed > 25km/h CP may select Category 1-1 and 1-2 and Category 2 with GVM less than 4536 kg, paragraphs 5 and 6 shall apply in accordance w/general requirements of paragraph 4 Category 1-2 and Category 2 with GVM greater than 3500 kg, requirements of paragraphs 7 and 8 shall apply in accordance with general requirements of paragraph 4 E.1.35 CP can exclude small vehicles Vehicles <350 kg (not including mass of traction batteries) with max speed less than 45 km/h and less than 4 kW max continuous rated power Vehicles w/unladen mass less than 450 kg or 650 kg (for vehicles carrying goods), less than 15kW max rated power Vehicles between 3500kg and 4536 kg CP can apply either paragraphs 5 and 6 or 7 and 8 depending on vehicle classification in domestic regulation

EVS-GTR Definition Comment Section Category 1 4+ wheels, passenger-carrying vehicle Category 1-1 <8 seating positions, in addition to driver’s seating; no standing passengers Category 1-2 >=8 passengers, seated or standing, in addition to driver Category 2 4+ wheels, goods-carrying vehicle including tractive units (e.g., forklift) and chassis designed specially to be equipped with special equipment 1.3. To determine whether a vehicle is to be regarded as a category 1 vehicle or a category 2 vehicle for the application of gtrs, the following shall apply in cases where it is not immediately apparent whether a vehicle is a category 1 or 2 vehicle: 1.3.1. If a vehicle meets all of the following conditions: P - (M + N x 68) > N x 68, N <=6 and Pay mass as defined in paragraph 7. of Annex 3 exceeds 150 kg for the vehicle, as configured with the maximum mass of factory fitted optional equipment, the vehicle shall be deemed to be a category 2 vehicle. In all other cases, the vehicle shall be deemed to be a category 1 vehicle. Where, P = Gross vehicle mass as defined in paragraph 4 of Annex 3. M = Mass in running order as defined in paragraph 3 of Annex 3. N = Maximum number of simultaneous seating and standing positions excluding the driver seating position

EVS-GTR Comment Rationale Low mass, low speed vehicles exempted Operate in lower speed environments, no need to meet high safety levels mandated for higher speed vehicles Low mass, high speed vehicles are covered Regulatory alignment with M and N vehicle categories is required with view to meet high safety levels because they are likely to be involved in accidents at higher speeds Heavy duty separated from LDV -Technical discussions would slow down HDV and thus jeopardize overall timeline of EVS-GTR Separate task force was formed to evaluate applicability of test and requirements from sole perspective of HDV and to propose alterations and exemptions when appropriate -Keep EVS-GTR user friendly by keeping PC/LDV -HDV and LDV have different technology solutions (e.g., charging technology: HDV to minimize human involvement). Separate requirements for LDV allows for future revisions when technology is more evolved -Each CP gets to choose if it wants to adopt HDV regulation -HDV is more of vehicle integrator that can produce both complete and incomplete vehicles (e.g., chassis). Another party is responsible for building the body. Also, HDVs can change applications and be rebuilt during its service life. Thus, conditions and limitations must be considered in detail for HDV especially for incomplete vehicle compliance. -Custom HDVs are common depending on application and customer. Component based testing is essential and NOT vehicle-based tests. -If not able to perform component level and vehicle test is unavoidable, must have a way to select a limited set of representative vehicle designs to test for compliance of the entire range. -When developing HDV, must ensure LDV ones do not become technology limiting for HDVs. This is important for criteria with high potential of becoming market normative.

FCEV-GTR Scope Comment Section All hydrogen fuelled vehicles of Category 1-1 and 1-2, with a gross vehicle mass (GVM) of 4,536 kilograms or less Heavy duty currently not included

Applicability to GTR13 HD Requirements/Rationale Apply to GTR13? Comments 1. Both LDV and HDV fall within the scope of EVS-GTR Yes 2. LDV requirements defined in EVS-GTR 3. HDV tests and requirements to be defined by separate task force at a later time 4. Each CP can decide to adopt HDV regulation 5. HDV testing should be component-based and not vehicle-based 6. If HDV component test not feasible, then must limit set of representative vehicle designs to test for compliance of the entire range 7. Must ensure LDV requirements do not become technology limiting for HDVs