India Comments on EPPR - 29-06

Comment-1 : Clause 4: Definition IMMA proposal is to keep all the definition in this document in alphabetical order. This can be accepted and its also suggested that all the definition in existing GTR-18 on OBD-1 can be also set in the alphabetical order. Comment-2 : Definitions Mono-fuel vehicle Powertrain Calibration Powertrain Control Unit Powertrain software IMMA Comments: Propose to delete because not used in this GTR2 India Comment: India does not agree to delete these definitions from GTR 2. These are required for GTR 18 ( Current and Proposed amendement under formulation in OBD2CG). In case EPPR agrees to delete these definitions need to be incorporated in GTR 18 itself.

Comment-3: Table -6 : Principal performance requirements under column reference fuel for PI & CI class mentioned references given for fuel are mentioned as Annex 40 which is not correct, it should be annex 4. This correction was proposed by India earlier. Table 7 Foot note 2: Applicable parts of driving cycle for Alt A are part 1 RS  cold and part 1 RS  hot, as  against Euro 4 part  1 RS  cold and part 2 RS  hot Comment-4:  IMMA Comments to change HC to THC and also to define RS can be included in a table of abbreviation and this table can be created. Similar such kind of terms can be brought under table of abbreviation for better clarity. Term Meaning HC Total Hydrocarbon THC RS Reduced Speed RST25  Reduced speed truncated at 25kmph RST45 Reduced speed truncated at 45kmph

Comment-5 : If IMMA would like to remove the Note number then the notes should be shifted to relevant clause. Comment-6 clause no 3.4.5.3.1.1.: India has already given comments on equation no 7 to replace Mk by Mref Comment-7: Clause no 3.4.6.1.2.1.: IMMA comment to add term ma in this clause for the sum of mass in running order is not appropriate As term ma is defined as actual mass in the table of symbols. Comment-8: Clause no 4.1.1. : As IMMA proposed to change GDI to DI, we recommend to replace GDI by Gasoline direct injection. However GDI is term used in most of the international regulation in different way.  

Comment-9: Clause no 4.2.2.2. , 4.2.2.2.2. , 4.2.2.2.6.1. & 4.2.2.3.1. : IMMA comments to be justified, however India feels Two wheeler configuration with twin wheel will require this clause. Comment-10: Clause no: 5.1.1.4.3.: IMMA comments to use “x” for multiplication in the formulae to be verified by secretariat to maintain the uniformity across the GTRs. Comment-11: Annex-2 clause no 5.3. : India Comment: (CCO + CCO2) is at least 15% for petrol (E5)     Justification:  Delete E5 and made it applicable for all.  

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