Fuel Cell Vehicles - Required corrections in xxx-2016 EU WLTP 10.11.2016, Brussels 2016

TOPIC LIST FOR FUEL CELL VEHICLES ATCT Application for FCHEVs FC calculation table should be corrected (align with ATCT scope = veh w/ tailpipe CO2) Hydrogen Fuel Quality H2 Ref fuel purity is not aligned with GTR#15/ISO14687-2(2012) & difficult to find in the market, it should be min 99,97%. Also other H2 characteristics need to be updated. Type Approval Character Matrix A type approval character should be defined for Fuel Cell Veh 1/18/20191/18/2019

ATCT APPLICATION FOR FCHEVs (1) Concern Currently there is an inconsistency in the draft regulation xxx/2016 regarding ATCT Correction for FCHEVs. See A & B A) Sub-annex 6a, par.1 1. Introduction This Sub-Annex describes the supplemental Ambient Temperature Correction Test (ATCT) procedure to determine the CO2 emissions under representative regional temperature conditions. 1.1. The CO2 emissions of ICE vehicles, NOVC-HEVs and the charge sustaining value of OVC-HEVs shall be corrected according to the requirements of this Sub-Annex. No correction is required for the CO2 value of the charge depleting test. No correction is required for an Electric Range.

ATCT APPLICATION FOR FCHEVs (2) B) Sub-annex 8, par 4.2.1.2. , Table A8/7 Calculation of final CS fuel consumption for NOVC-FCHVs Source Input Process Output Step no. Appendix 7 of this Sub- Annex. Non-balanced charge- sustaining fuel consumption FCCS,nb ,kg/100km Charge-sustaining fuel consumption according to paragraph 2.2.6. of Appendix 7. to this Sub-Annex FC CS,c,1 , kg/100km; 1 Output from step no. 1 of this Table. REESS electric energy change correction Sub-Annex 8, paragraphs 4.2.1.2.2. to 4.2.1.2.3. inclusive of this Sub-Annex FC CS,c,2 , kg/100km; 2 Output from step no. 2 of this Table. ATCT correction according to paragraph 3.8.2. of Sub-Annex 6a. Deterioration factors calculated according to Annex VII. FC CS,c,3 , kg/100km; 3 "result of a single test" Output from step no. 3 of this Table. For every test: FC CS,c,3 , kg/100km; Averaging of tests and declared value according to paragraphs 1.1.2. to 1.1.2.3. inclusive of Sub- Annex 6. FC CS,c,4 , kg/100km; 4 Output from step no. 4 of this Table. FC CS,c,4 , kg/100km; FC CS,c,declared , kg/100km Alignment of phase values. Sub-Annex 6, paragraph 1.1.2.4. And: FC CS,c,5 = FC CS,c,declared FC CS,c,5 , kg/100km; 5 " FC CS results of a Type 1 test for a test vehicle" “3.8.2. The CO2 values for each vehicle within the ATCT Family (as defined in paragraph 2.3. of this Sub-Annex)” Supplementary note: reference paragraph in 3.8.2 should be corrected from 2.3 to 3. (3. ATCT Procedure)

ATCT APPLICATION FOR FCHEVs (3) Conclusion & xxx/2016 correction proposal We believe that ATCT correction should only be applied to vehicles emitting CO2, as indicated in Sub-annex 6a scope. Therefore it should not apply to neither PEVs nor FCHEVs, as they do not have tank-to-wheel CO2 emissions. In the current draft regulation it is unclear/ inconsistent the requirement for FCHEVs. ATCT correction should be removed from Sub-annex 8, par 4.2.1.2. , Table A8/7 (Calculation of final CS fuel consumption for NOVC-FCHVs)

Hydrogen Fuel Quality (1) Background Minimum Fuel Cell Hydrogen reference fuel purity 630/2012 amending 692/2008 → 99,99% (ANNEX IX - SPECIFICATIONS OF REFERENCE FUELS) GTR#15 → 99,97% (ANNEX 3 – REFERENCE FUELS) Xxx/2016 → 99,99% GTR#15 and EU Regulation requirements are not aligned The original ISO14687-2 (2008) mentioned 99.99%, but it was revised to 99.97% from ISO14687- 2(2012)

Hydrogen Fuel Quality (2) Concern As vehicle manufacturers we welcome better Fuel Quality requirements, however we need to be able to source the reference fuel In this case, 99,99% purity is an unnecessarily high requirement Our Hydrogen fuel supplier informed us that 99.97% is the technically feasible limit, 99.99% can only be achieved randomly (cannot be guaranteed) If 99,99% requirements is kept, we will struggle to find reference fuels in the Market. H2 purity requirement should be aligned with GTR#15/ ISO14687- 2(2012) (99,97%)

Hydrogen Fuel Quality (3) Xxx/2016 Concern GTR#15/ ISO14687- 2(2012) also updated other hydrogen requirements, not up-to-date in xxx/2016 GTR#15

Type Approval Character Matrix(1) Background Annex I Appendix 6 (EC type-approval certificate numbering system) 692/2008 Xxx/2016

Type Approval Character Matrix (2) Concern The type approval character for Fuel Cell Vehicles (FCVs) has disappeared in xxx/2016, and PEV character is duplicated. AY character should be re-assigned to Fuel Cell Vehicles, so this type of vehicles can have a type approval character. In addition, we believe that the implementation dates of AY (and AX/AZ) should be made consistent with those of xxx/2016. "Fuel cell vehicle" (FCV) means a vehicle equipped with a powertrain containing exclusively fuel cell(s) and electric machine(s) as propulsion energy converter(s)