India Comments on EPPR-14-06e Proposal for a new Global technical regulation on the measurement procedure for two- or three-wheeled motor vehicles with regard to on-board diagnostics

India comments – deletions are marked in double strikethrough and additions in this font. Clause NoProposed changeJustification Section I - Statement of technical rationale and justification Para D, Figure 1 1 st decision box “OBD Stage I system …… scope of Annex 2 ? Either Table 4 or Table 5 as per the applicability of Grade A or Grade B or Grade B enhanced“ For better clarity Para D, Figure 1 2 nd Decision box “Does contracting party ….. (options Either Table 4 ? or Table 5 )“ For better clarity Para D, Figure 1 3 rd Decision box “Fail the enhanced ….. thresholds ? ”Editorial D(3)(c ) Following sub-para (c) of running para in Section I-D(3) may be deleted. (c)motor vehicles complying with the following criteria: (i)three wheels; and (ii)in which the arrangement of the wheels is symmetric with respect to the longitudinal centreline of the vehicle; and (iii)the distance between the lines passing through the centres of the ground-contact sections of the outermost wheels on the axle on the same line is less than 460 mm; and (iv)constructed to turn with part or all of the wheels and vehicle body inclined. “ India accepts the proposal to include scope of three wheelers in line with the practice accepted for GTR for Type III and IV tests. This para is related to three wheelers criteria and may be deleted in line with the discussion in GTR for Type III and Type IV tests. D (7) (26) The reference fuel shall be ……… OBD verification testing than that used for Type I ……………………” Editorial

India comments – deletions are marked in double strikethrough and additions in this font. Clause NoProposed changeJustification Section II - Text of the global technical regulation 2 2. Scope and application Two- [and three-] wheeled motorcycles vehicles of category 3 2 equipped with a propulsion unit in accordance with Table 1. it is necessary to remove square bracket regarding three wheelers at all places. Also, an editorial correction is needed in this para to replace word ‘motorcycles’ to ‘vehicles’. 2, Table 1 Scope with regard to the propulsion unit and fuel type 1. Type VIII test is described as optional, depending on the grade of OBD and MIL operating criteria. (See Annex 3, clause 1.1). Hence Note (1) should be applicable to all types described in this table. The reference to the foot note may be shifted to the heading. 2. Similar to the exempting hybrid and electrical from the table, it is suggested that Hydrogen fuel vehicles may also be exempted. At the moment, there is no identified plan of work to decide on the pollutants permitted from a Hydrogen fuel vehicle. Once this is introduced in GTR 2, suitable amendment can be issued to this GTR. 3. Since the exemption of bi-fuel vehicle, with a limited tank capacity, is already specified in the table, it is no longer necessary for an option to CP to restrict OBD only for one fuel in the case of bi-fuel vehicles. Hence reference to note 2 may be deleted. 4. Explanation paragraph needs a change to include 3 liter capacity in the case of three wheeled vehicles. Text suggested as per Evapo GTR. Propulsion unit and fuel type Functiona l OBD Test type VIII (1) Vehicle with PI engine Mono-fuel* Petrol Yes(1) LPG [Yes][(1)] NG / Biomethane [Yes][(1)] Hydrogen [Yes][(1)] Bi-fuel PetrolLPG [Yes][(2)] PetrolNG / Biomethane [Yes][(2)] PetrolHydrogen [Yes][(2)] Flex-fuel PetrolEthanol (E85) [Yes][(2)] NG / Biomethane HCNG [Yes] [(3 2 )] Vehicle with CI engine Flex-fuelDieselBio-Diesel [Yes] [(4 3 )] Mono-fuelDiesel Yes(1) Pure electric vehicle or vehicle propelled with compressed air (CA) -[No]- Hydrogen Fuel cell vehicle -[No] (1) At the discretion of the Contracting Party (2) Petrol only, at the discretion of the Contracting Party (3 2 ) NG/Biomethane only, at the discretion of the Contracting Party (4 3 ) B5 only, at the discretion of the Contracting Party Exemption: OBD requirements are exempted in petrol mode of a monofuel motor vehicle that is designed primarily for permanent running on LPG or NG / bio-methane or hydrogen, having a petrol system, with a petrol fuel tank capacity not exceeding two litres in the case of two-wheeled motorcycles and motorcycles with sidecar and not exceeding three litres in the case of three-wheeled vehicles, intended for emergency purposes or starting only.

India comments – deletions are marked in double strikethrough and additions in this font. Clause No Proposed changeJustification Section II - Text of the global technical regulation “calculated load value” means referring to an indication of the current airflow divided by peak airflow, where peak airflow is corrected for altitude, if available, or using any other load variable (see Annex I Clause 3.1.3). This definition provides a dimensionless number that is not engine ‑ specific and provides the service technician with an indication of the proportion of engine capacity being used (with wide open throttle as 100%); India appreciates inclusion option of the alternative methods for calculating the load value. (Annex I, para no ) However, the definition given in Section II, 3.2 describes only the air flow method. In order to bring in more clarity it is suggested that this para may be modified “malfunction indicator” (“MI”) means a visible or audible indicator that clearly informs the driver of the vehicle in the event of malfunctions; -needs more discussion. MIL with audible indicator is a new concept – need to be discussed how it can be implemented by authority to serve the purpose of OBD "useful life" means the relevant period of distance and/or time over which compliance with the evaporative total hydrocarbon emission limits has to be assured. - needs discussion. 1."useful life" definition is not clear as it has to take care of all the gtr’s related to environment performance. Need discussion. 2.‘useful life’ definition in this GTR is copied from Evapo GTR. India would like to understand the intention of the definition wrt OBD since no qualitative requirements are specified in this GTR. General requirements are covered in Section II, Para 5.1 & in relation to useful life. 3.Also ‘Useful life’ definition does not exist in ECER 83, EU regulations for OBD provisions “warm-up cycle” means vehicle operation …… cylinder head surface may be selected. India suggest to use ‘first cycle used in type I test’ in ‘warm up cycle’ definition. India suggest to use ‘first cycle used in type I test’ in warm up cycle definition based on the CP defined type I test driving cycle.

India comments – deletions are marked in double strikethrough and additions in this font. Clause NoProposed changeJustification Section II - Text of the global technical regulation Delete this clause By [01 January 2020] the list in Table 5 of Annex 2. shall be reviewed and updated for technical progress if deemed necessary. The limited elements of Grade A may at any moment be expanded with additional elements from Table 5 of Annex 2 at the discretion of the Contracting Party. Clause to be deleted as any future relevant amendment to GTR to address the change in the technology can be brought in by CP’s though regular administrative procedure Annex I, 3.1 Except in the case of grade A OBD I, upon determination of the first malfunction of any component or system, “freeze-frame” engine conditions present at the time shall be stored in computer memory. Stored engine conditions shall include, but are not limited to, calculated load value, engine speed, fuel trim value(s) (if available), fuel pressure (if available), vehicle speed (if available), coolant temperature (if available), intake manifold pressure (if available), closed- or open-loop operation (if available) and the diagnostic trouble code which caused the data to be stored. India’s proposal in EPPR12-14e was to exempt freeze frame storage parameter conditions for Grade A type OBD I since this is not relevant at Grade A only circuit continuity is checked and MIL gets ON Annex I, Except in the case of grade A OBD I, The manufacturer shall choose the most appropriate set of conditions facilitating effective and efficient repairs in freeze-frame storage. Only one frame of data is required. Manufacturers may choose to store additional frames provided that at least the required frame can be read by a generic scan tool meeting the specifications of points 3.9. and If the diagnostic trouble code causing the conditions to be stored is erased in accordance with point of Section II the stored engine conditions may also be erased.

India comments – deletions are marked in double strikethrough and additions in this font. Clause NoProposed changeJustification Section II - Text of the global technical regulation Annex I, 3.2 Except in the case of grade A OBD I, If available, the following signals in addition to the required freeze-frame information shall be made available on demand through the serial port on the standardised diagnostic connector, if the information is available to the on-board computer or can be determined using information available to the on-board computer: diagnostic trouble codes, engine coolant temperature, fuel control system status (closed-loop, open-loop, other), fuel trim, ignition timing advance, intake air temperature, manifold air pressure, air flow rate, engine speed, throttle position sensor output value, secondary air status (upstream, downstream or atmosphere), calculated load value, vehicle speed, the position of the antilock brake system switch (on/off), the activated default mode(s) and fuel pressure. The signals shall be provided in standard units based on the specifications in point 3.7. Actual signals shall be clearly identified separately from default value or limp-home signals. The type and details of whichever data to be stored as freeze frame, will be at the choice of the manufacturer as required to adequately demonstrate the ability to understand suitably the failure mode and conditions. Same as above Annex II Table 4- 1st row 2nd column “Limited to sensor circuits only, item Nos 2, 4, 5, 10, 11, 12, 15, 17, 18, 21. Sensor circuits are to be monitored for electric circuit malfunctions, open/short circuit failures.” Sensor at item no. 21 is ‘Throttle position sensor’ which also needs to be monitored in grade A.

India comments – deletions are marked in double strikethrough and additions in this font. Clause NoProposed changeJustification Section II - Text of the global technical regulation Table 4 Grade A Grade B Grade B plus Enhanced As “OBD Grade B plus enhanced” is not clear hence new column added for clarity Table 5 Limited to sensor circuits only, item Nos 2, 4, 5, 10, 11, 12, 15, 17, 18., 21 Sensor circuits are to be monitored for electric circuit malfunctions, open/short circuit failures. Any other sensor or actuator circuit declared by the manufacturer. Option fuel trim diagnosis --  Option Annex 3-- Option OBD fail thresholds set out in domestic legislation -- 

India comments – deletions are marked in double strikethrough and additions in this font. Clause NoProposed changeJustification Section II - Text of the global technical regulation Annex III Delete this clause: The environmental OBD verification and demonstration tests shall be carried out on a test vehicle that shall be properly maintained and used, dependent on the chosen test type V method on durability requirements of pollution control devices at the discretion of the Contracting Party. India had suggested deletion of Clause & Annex 3, which calls for checking on a vehicle which has undergone type test. Here, reference to Type V test which is not defined in GTR is not appropriate. However, clause 4 adequately defines the procedure for OBD environmental test Annex III Delete this clause: The test vehicle(s) shall be equipped with the aged emission components used for durability tests. The OBD environmental verification tests are to be finally verified and reported at the conclusion of the Type V testing on the durability of pollution control devices; Annex 4 Table 6 Sl.no 1.1 Category; Note: Two-wheeled motorcycles and two-wheeled motorcycles with sidecars are considered to be of the same family. Generally Motorcycle and motorcycle with side car will have same propulsion unit and OBD system, in that case both vehicles shall be considered under one family. Annex 4 Table 6 Sl.no 2.1 “number of engines or electric motors” Hybrids and electric vehicles have been removed from the current scope and hence, references need to be removed. Over and above the one indicated in serial no. given below, the following corrections are proposed. Annex 4 Table 6 Sl.no 2.1 “hybrid operation mode(s) (parallel / sequential / other);” General Comment India suggest to standardise the RMI formats with the agreed information which will be followed by contracting parties. We need to further discuss to explore the possibility of evolving harmonized procedure on this item.

Thank you