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

2. 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/ISO (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

3. 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.

4. ATCT APPLICATION FOR FCHEVs (2)
B) Sub-annex 8, par , 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  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 to 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 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 to 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
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"
“ 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 should be corrected from 2.3 to 3.
(3. ATCT Procedure)

5. 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 ,
Table A8/7 (Calculation of final CS fuel consumption for NOVC-FCHVs)

6. 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 ISO (2008) mentioned 99.99%, but it was revised to 99.97% from ISO (2012)

7. 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/ ISO (2012) (99,97%)

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

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

10. 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)