1. ACEA comments on EU WLTP issues EU WLTP, 2 ND OF FEBRUARY 2016 1 02 February 2016

2. Overview EU WLTP ACEA VIEW  If ACEA misunderstood some of the achieved compromises, ACEA is ready to repeat their arguments.  WLTP should be harmonized, accurate, repeatable, representative, error-free and feasible. IssueCurrent statusACEA viewWay forward Type definitionUnclear situation. The achieved compromise was not applied. The vehicle type definition is a core element in terms of effort and workload. It should be carefully chosen. discussion needed COP evolution factor Instead of the discussed value of 4-5%  3% are drafted. Why? Measuring "Evo-factors" for the majority of the vehicles increases test burden in an unnecessary manner. A higher value is justified. See ACEA proposal. discussion needed COP of Eco- Innovations Open. Discussed compromise was dropping that requirement. Measurement is a huge effort, vehicles may have to be re-built. Requirement should be dropped. conformation needed Number of tests A reasonable compromise was discussed in last EU WLTP. ACEA has provided that possible compromise values as separate slide. decision needed Drive trace correction Unclear. Is there a proposal?Discuss and further develop within WLTP phase 2. Currently no validation available. discussion needed TransparencyAccess and communication of dyno mode is an open discussion. Transparency is welcomed as long as it not violates safety issues, data privacy or undermines competitiveness of European industry. discussion needed Evaps2 parallel plans – EU & WLTPWork with the IWG WLTP to develop an harmonised procedurediscussion needed

3. Within a "TA-TF" phone conference (11/2015) a first ACEA proposal was rejected and as a possible compromise by adding some of the RDE family criteria was proposed. ACEA therefore improved the proposal accordingly, which is a fair and reasonable approach. See box  The current EU Commission proposal of taking the "Interpolation Family" is unworkable: Many "Interpolation Families" are so similar, that >99% of the approval data are identical. Therefore it is more transparent to include them in one and show differences, than sending in another huge package of paperwork. Secondly very small changes (e.g. n/v ratio) would request a new type and therefore application of new regulations (e.g. OBD, evaporative emissions, …) which is not justified economically and probably even impossible (engine development program). ACEA proposal for type definition FUNCTIONAL TYPE DEFINITION "Functional Type " / "Emission Type" / "Certification Type" Propulsion type (e.g. ICE, HEV, PHEV) Type(s) of fuel(s) (e.g. petrol, diesel, LPG, NG, …) Combustion process (e.g. two stroke, four stroke) Number of cylinders Configuration of the cylinder block (e.g. in-line, V, radial, horizontally opposed) Method of engine fueling (e.g. indirect or direct or combined injection) Method of aspiration - naturally aspirated or pressure charged Maximum power (up to 50%) cylinder deactivation Type of cooling system (e.g. air, water, oil) Types and sequence of exhaust after-treatment components (e.g. three-way catalyst, oxidation catalyst, lean NOx trap, SCR, lean NOx catalyst, particulate trap). Exhaust gas recirculation (with or without, internal/external, cooled/non-cooled, low/high pressure

4. Data are filtered for outliers and vehicles, where "zero" km were above 120 km. But picture is very similar for unfiltered data. Source: Presentation from 04/2015. 0.97 appear to be too small, a factor of 0.95 or below is justified. Proposed value of 0.97 too small and not justified EVOLUTION FACTOR FOR COP TESTING Source: BAST / DEKRA study Proposed 0.97 cover less than 50% of the vehicles. Majority of tested vehicles have higher values than the 3%. For these additional testing would be required  unnecessary effort!

5. Current text for COP testing: Imagine testing a vehicle with and without engine insulation. Testing as described in the application to demonstrate the CO 2 -potential requires several tests with and without engine insulation.  Vehicle will have too much kilometres to be sold to the customer.* (It already receives ~100km in a normal COP.)  Vehicle is somehow damaged by the rebuilding due to different hardware requirements.  Additional soak chambers required. Why should an Eco-Innovation work differently in a customer vehicle? If so, a re-certification would be required anyway. COP is a quality check, not a functional test. Proposal: Do not require testing. Require a check, that this eco-innovation is actually installed in the vehicle in the type approved form. E.g. by checking serial- / type-numbers of relevant parts or components. Effect and way forward COP FOR ECO INNOVATIONS *Some may argue: "Why not selling as a used car and building a new one for that customer?" But then in fact you built a vehicle for the purpose of COP-testing, which is obviously not in the spirit of COP-testing.

6. NUMBER OF TESTS. NO DECISION IN EU WLTP UP TO NOW. JRC analysis shown in correlation group 10/2015: Accuracy increases only by 0.43 g/km by going from 1 to 3 measurements. Is that huge burden justified by a potential influence of 0.4 g/km?

7. During last EU WLTP the proposal presented here was already seen as possible compromise. WLTP Round Robin Testing has shown a very good repeatability within one lab. So the fear of gaining a benefit by "cherry picking" is not supported by data*. ACEA proposes to adopt values, that are justified by data. See table. * More than a threshold of 0.5% for one test cannot be argued by the data presented by JRC. The huge difference between labs is not addressed by that concept. NUMBER OF TESTS - PROPOSAL number of tests123 dCO2-value, proposal0.9951.000 CO2-disadvantage0.5%0% testing burden (# of dyno tests for one vehicle) 61014

8. The principle of achieving more accurate results is welcomed. But the current discussion is far away from a robust concept:  Hybrids not addressed.  Correction function is not validated by measurements.  Analysis within phase 1 shows a lack of consistency (EER).  No text proposal available. This issue is on the agenda in phase 2 in WLTP, where it can be assessed in an appropriate manner. GTR requires a monitoring of that indices, which should be the necessary input to derive tolerances or corrections. EU idea of correcting for drive trace deviations DRIVE TRACE CORRECTION FUNCTION Document from WLTP Phase 1.

9. The "dyno mode" deactivates safety systems during a chassis dyno test in order to enable proper testing (e.g. "ESP", traffic jam assist, etc.). Otherwise the vehicle would activate the brakes – as in such a case on the road – and no valid test would be possible. Deactivating such features is a severe safety issue, if it would occur in normal driving. Therefore the procedure, how to enter the dyno mode, is not public. Remark: A list of deactivated devices by the dyno mode is part of the approval process. It is understood, that there should be a possibility for independent dyno testing of vehicles. In that case the activation of the dyno mode should be requested from the authority, where that procedure should available (communicated to the authority by the OEM in conjunction with the approval). How and where to provide data? TRANSPARENCY AND COMMUNICATION

10. General situation EVAP TEST PROCEDURE Currently, several CPs are in the middle of rule making process of new Evap test procedure. Those procedures should be harmonized as much as possible. For this purpose, Japan e.g. proposes to: finalize the Evap test procedure for GTR during phase2a (i.e. by the end of 2016). establish “EVAP Task Force” as standalone task force to accelerate the discussion and get the new procedure completed in time.

11. Time line EVAP TEST PROCEDURE

12. Thank you for your attention www.acea.be