1. OBD2CG-11-06 OBD2 Phase 1 consolidated draft
India Comments on
OBD2CG OBD2 Phase 1 consolidated draft

2. Comment-1: General Requirements Clause no 5. 3
Comment-1: General Requirements Clause no 5.3.9: Manufacturers may demonstrate to the approval authority that certain components or systems need not be monitored if, in the event of their total failure or removal, emissions do not exceed the emission OBD threshold limits given in [paragraph 5.5.1]. Justification: To commonise the text throughout this document along with the title of paragraph of Comment-2: Clause no : Manufacturers may adopt higher misfire percentage malfunction criteria than those declared to the authority, under specific engine speed and load conditions where it can be demonstrated to the authority that the detection of lower levels of misfire would be unreliable. In terms of OBD monitoring, it is that percentage of misfires out of a total number of firing events (as declared by the manufacturer) that would result in emissions exceeding the OBD threshold limits set out in [paragraph ], or that percentage that could lead to an exhaust catalyst(s), or catalysts, overheating, causing irreversible damage. Justification: Removal of redundant text.

3. Comment-3: Clause no : The MI shall also activate when the vehicle's ignition is in the 'key on' position before engine starting or cranking and deactivate after engine starting if no malfunction has been detected. For vehicles not equipped with a battery, the MI shall illuminate immediately after engine starting and shall subsequently be deactivated after 5 seconds, if no malfunction has previously been detected In Alignment with R83 Justification: To align with UN R-83 requirements and also give clarity on the ambiguity for MI deactivation. Comment-4: Annex 2 Title: Minimum monitoring requirements for electric circuit diagnostics of an On Board Diagnostic (OBD ) system Justification: India Proposal was accepted on 5th June 2018 (OBD2 2nd Session-24th EPPR), however not reflecting in the final consolidated version of OBD-2 document. This is an editorial comment

4. Comment-5:
Annex 6, clause no 1.2: The manufacturer shall make available the defective components or electrical devices to be used to simulate failures. When measured over the appropriate test type I cycle, such defective components or devices shall not cause the vehicle emissions to exceed by more than 20 percent the OBD threshold limits set out in [paragraph ] of general requirements. For electrical  failures (short/open circuit continuity/ circuit rationality/basic monitoring requirement), the emissions may exceed the OBD threshold limits set out in [paragraph ] of general requirements by more than twenty per cent.
Justification: To bring clarity:
Electrical failure will not cover Circuit Rationality & basic monitoring in totality hence text is proposed to be modified as “for electrical failure …..”
To bring clarity to the clause inline with the Table-1 of Annex 2, the failures to be monitored are covered by clear terms as “ Circuit continuity/circuit rationality…..”

5. Annex 6 Comment-6: clause no 8. 3. 1
Annex 6 Comment-6: clause no : Electrical disconnection of any other emission-related component connected to a powertrain control unit / engine control unit (if active on the selected fuel type) in the scope of [Annex 2]; Justification: Scope of this GTR is mono fuel only, Hence selection of fuel has no relevance. Comment-7: clause no : Electrical disconnection of the electronic evaporative purge control device (if equipped and if active on the selected fuel type). For this specific failure mode, the type I test need not be performed. Justification: Scope of this GTR is mono fuel only. Hence selection of fuel has no relevance.

6. Comment-8:
Annex 6: clause no : Electrical disconnection of the electronic evaporative purge control device (if equipped and if active on the selected  fuel type);  
Justification: Scope of this GTR is mono fuel only. Hence selection of fuel has no relevance.
Comment-9:
Annex 7: Clause no 2: A representative parent vehicle shall be selected within the boundaries set by the classification criteria laid down in [Table 1 of paragraph  3 Annex 7 or table XX of annex 5]
Justification:
Paragraph 3 is not in the Annex 7 of this document, hence deleted and Table 1 of Annex 7 is incorporated for clarity.
Place holder to be made for Table XX of Annex 5.

7. THANKS