EPPR-04-13e

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Working Paper No. EPPR-04-13e
Draft minutes
4th EPPR Informal Working Group Meeting, 8-9 October 2013
Pune, India
1.
Welcome and introduction
Mr. Marathe welcomed the group at ARAI. The Chairman thanked ARAI for hosting this meeting and also
thanked SIAM for the dinner the evening before.
2.
Adoption of the draft agenda
No comments from the group
3.
Draft Minutes of 3rd meeting and operational conclusions from phone meeting on 13th Sept
document EPPR-03-08-Rev1e + EPPR-03-09e
document EPPR-04-05e
No comments on the amendments to the minutes. Adopted.
4.
Report on EPPR Terms of Reference and rules of Procedure and EPPR mandate from GRPE
The Chair explained that GRPE agreed to the document in June 2013, and it was annexed to the GRPE report.
And end June, at WP29, it was introduced by the European Commission (EC). It will become an official document
for the WP29 of November 2013.
5.
Contributions from stakeholders (up-date of state-of-play or plans for coming regulations from contacting
parties)
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document EPPR-04-010e (EC), page 1 – 16
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EC provided an update of the regulatory process for L-category vehicles in EU. The co-decision framework
regulation has been published earlier this year and EC provided highlights of it. Delegated and implemented
acts are expected to be finalized soon and published in the course of next year. The EC delegated act REPPR
is expected to be adopted by EC earliest in December 2013.
EC also explained the Euro 3 step for mopeds, which was adopted earlier this year and is expected to be
published in Dec 2013. Date of first application: 01 Jul 2014. This step does not change limit values, but
changes the test procedure/cycle: Under Euro 2 cold start emissions were not measured, but from Euro 3
cold start emissions will be included with a 30% weight.
To a question of India, EC explained the meaning of a ‘delegated act’: EC is empowered by the Council and
the European Parliament to propose and adopt technical acts like the REPPR.
India asked about the action plan in EU. EC explained that there will be an environmental study in EU, and
that the definition and preparation of the study is currently worked out; In December a generic outline will
be presented and more detailed discussions with stakeholders will take place.The goal is to start the actual
study in the last part of 2014; EC will share info with EPPR on that in coming meetings.
India asked if it is legally possible to have amendments to the framework regulation 168/2013. EC confirmed
this is possible and that there is e.g. a build-in procedure to include new technologies. EC added that some
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corrigenda may be made too. And as for the delegated acts, especially for REPPR, there will be the
environmental study which may or may not result in amendments in the future.
Japan noted that drafting in EU will be closed soon, and asked how the work of our group (EPPR) will be
reflected in REPPR. EC explained they would like to replace REPPR with references to international
legislation, in particular to UN Regulations on the mid to long term. EC wants to give planning security to
OEMs until 2020-2021, but beyond 2020 the EU regulation may be amended by incorporation of these
reference to UN Regulations.
Finally India asked if existing vehicles will be affected from 2016. EC replied there would be one year extra
(to 2017) for existing vehicles, but this is not the case for all L-categories / all subjects. EC referred to the
transitional provisions in Article 77 and the detailed application times set out in Annex IV of Regulation
168/2013. EC offered to provide more detailed info separately.
6.
Proposals for new or amended GTRs and/or UN Regulations with regard to EPPR.
6 b.
Proposals for new GTR on Evaporative emissions (EVAP - Test type IV) and Crankcase (Test type III)
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document EPPR-04-09e (TRL-Ecorys)
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TRL provided an update on their work and explained how the proposals for Type I, EVAP, OBD and durability
are developed.
A more detailed introduction was given on the proposal for a new GTR on crankcase and Evaporative
emissions (EVAP) containing a list of cascading test procedures:
And finally TRL introduced the impact assessment performed by Ecorys.
The Chairman clarified the role of TRL: They are consultant for the EC, supporting EC to make proposals.
document EPPR-04-08e (Japan), page 2-8
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Japan explained the general process and planning of their domestic legislation process, followed by a
detailed update of the status of discussions for evaporative emissions. Starting point of discussion in Japan
was the SHED-test, as laid down already in California by CARB, (same starting point as EU).
Having compared their draft domestic regulation with the proposed in the draft EU-regulation (REPPR),
Japan found some differences:
1. Japan will clearly specifying the number of test cycles needed for preconditioning.
2. Test vehicle soaking time: Japan will follow the classification as in the CARB regulation.
3. Test vehicle conditions - Canister ageing:
 Japan said they look forward to receive background from EC on their proposal in REPPR.
 Japan will allow vehicle based ageing (according to Japanese full distance durability test).
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 For bench ageing, Japan would allow both methods specified by REPPR and by CARB.
 Japan will not apply a fixed DF.
4. Fuel Tank heating profile for the Diurnal Breathing Loss test: Japan considers to add a definition of
“non-exposed fuel tanks”
IMMA raised a concern regarding the differences in the draft EU and Japanese regulation, which could make
full harmonization difficult. EC replied that the draft REPPR could be changed on some details brought
forward by Japan up until 6 November 2013 and that EC is open to discuss the raised issues with all
stakeholders.
India asked if different soak times will have any influence on the measurements. Japan replied they don’t
have the background data available.
Regarding the method for non-exposed fuel tanks, India asked how the temperature will be monitored: fuel
vapour monitoring or direct fuel temperature monitoring? Japan said they proposed to check both.
India asked if there is a correlation between these two temperatures, and which should be the principal
sensor signal responsible to control the soak time. Japan said both are controlled.
To a question about the justification to introduce evaporative emission requirements, EC replied there is
limited data available in an impact assessment that was done at EU side.
document EPPR-04-010 (EC), page 40 – 45
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As a general introduction, EC explained that their proposals should be considered as a starting point for
discussion. EC does not want to impose anything on other Contracting Parties.
EC clarified that Type III is included, but that they are aware that it is not the priority set by the group, and
that it can be discussed at a later point of time.
EC explained the regulatory situation for EVAP in EU:
o Base test procedure: fuel tank permeability test for all L-category vehicles equipped with nonmetallic tanks already in current type-approval requirements;
o Sealed House Evaporative emission Determination (SHED) test will be applied for categories L3e
(two-wheel motorcycle), L4e (Motorcycle with side-car), L5e-A (Tricycle), L6e-A (Light on-road quad),
L7e-A (Heavy on-road quad) from Euro 4 onwards.
o For categories L1e-A (powered cycle), L1e-B (Two-wheel moped), L2e (Three-wheel moped), L5e-B
(Commercial tricycle), L6e-B (Light Quadrimobile), L7e-B (Heavy all terrain quad) and L7e-C (Heavy
Quadrimobile) two options remain open for Euro 5:
 SHED test
or
 Fuel tank and lines permeation test, based on US EPA requirements.
The EU emission effect study will determine which of the 2 options will be applicable, cfr. Article
23(4 -5) from L-cat Reg. Co-decision act 168/2013. Background: According to US EPA, the
permeation test is sufficiently cost-effective.
o Vehicles subject to SHED are not required to do permeation and permeability.
Vehicles subject to permeation , are not required to do permeability testing.
As such EC proposes to harmonise at different levels for a GTR:
o Permeability: non-metallic fuel storage
o Permeation: fuel storage and supply system
o SHED test: entire vehicle
EC suggested that references to technical standards (currently SAE) to be harmonised through CEN / ISO.
And EC also suggested to discuss whether or not also test limits can be harmonized, though this should not
have the highest priority.
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IMMA would like to start with L3, in order to get something by the end date (2016).
India thanked both Japan and India for providing their views, and added they need time to study and
understand the proposals.
IMMA agreed that the GTR cannot refer to SAE, instead reference to ISO should be made.
EC said they could help via CEN, in order for them to discuss with ISO. IMMA replied that ISO attends WP29,
so communicating with them should be easy.
The Chair said that EVAP is one of top priorities of the group, if not the highest priority.
document EPPR-04-06e (EC)
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24 Sep 2013 EC submitted a draft proposal for a gtr covering test types III (crankcase emissions) and IV
(evaporative emissions).
EC explained amongst others that:
o the document has a modular structure:
 Crankcase
 Evaporative, test types (permeability, permeation, SHED)
 And a common part for the test types
o the cost of the ageing procedure is to be further assessed in the environmental study.
o the proposal includes a ‘family definition’.
The Chair understood that most participants need more time to review the document and that it will be
necessary to come back to it . It was suggested to discuss it again in a phone meeting at a later stage.
IMMA suggested to narrow the scope to L3 categories, and to explore later if other categories can follow.
EC did not want to get stuck on the scope, but was concerned that if it is chosen not to cover 3-wheel
vehicles now, there is a risk that we will end up with different requirements for 3-wheelers.
India suggested to separate Type III and IV, and added that L3 and L1 should get priority.
EC suggested to keep the title/scope: a GTR for 2 and 3-wheel vehicles, and keep an empty annex for 3wheel vehicles.
The chair considered this as a potential way forward, to be discussed again.
IMMA suggested to put 3-wheelers in brackets, but focus on L3.
Japan said it has a similar stance like IMMA, and that they don’t want to oppose the discussion on 3-wheel
vehicles.
The Chair reminded about the concern raised by the GRPE chairman that it is a problem to have overlap of
scopes.
The Chair asked Japan if they could consider other than L3-vehicles. Japan replied they need to discuss this
internally first.
India said that it was discussed at the beginning to give priority to L3, and later L1 was added on request of
EC.
India also said that a validation has to be done for L3 and L1 first before an extension to other categories can
be considered.
EC suggested to perform a limited validation program, and to consider different models.
The chair summarized that there should be a focus on L3 and L1, and that this should be the basis for
developing the GTR. But we should consider the possibility to include 3- and 4-wheel vehicles at a later stage.
The chair took note of the concern by India regarding the need for validation.
The chair invited the group to table comments and/or amendments in the next months, and suggested to
have a phone meeting before next GRPE in January 2014.
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Document EPPR-04-12e
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6 c.
It was discussed how comments should be kept. One option was to use the document provided by EC and to
keep track of changes. The chair was concerned warned such document could become difficult to overview.
The secretary suggested to consider composing a separate document with issues and possible solution, like
was used within WLTP working groups.
Regarding crankcase emission, the chair suggested to keep it together with EVAP, however as it is not the
main priority, keep it as a placeholder.
Japan could accept to keep the text for crankcase in brackets, and to come back to it later.
IMMA also supported this.
India also prefers to keep discussion on EVAP and crankcase emissions separate.
China, participating remotely, had some questions about the type IV (evaporative emission) test and the proposal
by EC. They questions were answered by EC.
o China: How to understand the fixed DF in respect to the limit value?
EC: With reference to the bottom of slide no. 3 in the presentation document by Japan (EPPR-04-08e), it
was indeed confirmed that if the limit is 2000 mg/test, with a fixed deterioration factor of 0.3 g/test, the
result of the SHED test shall stay below 1700 mg/test.
o China: Why is the DF=0.3g/test?
EC: This comes from Federal US requirements.
o China: Why was the durability test option (vehicle based ageing) removed for ageing of the canister?
EC: In the end the process of legislation making was such that 2 methods survived.
Proposals for new GTR on OBD (Test type VIII)
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Document EPPR-04-08e (Japan), page 9-14
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Japan explained the status of their OBD study for domestic regulation:
o Japan’s OBD regulation for motorcycles will be applied for new vehicle types from end of 2016,
same as for EVAP. The final draft will be completed by the middle of 2014, same as for EVAP.
o Starting point is the existing J-OBD regulation for passenger cars.
o Discussion is still on-going.
o Scope is only L3 gasoline at this time.
o The regulation will only check for short/open circuit.
o Functional requirements:
 MIL (ISO 2575 conforming) to be stored in the ECU.
 Connector and adaptor to be ISO 15031-3 confirming
o Contrary to the EU regulation, the Japanese regulation is considering to exclude:
 Rationality check
 Emission thresholds
 Repair and Maintenance Information (RMI).
EC said they see a lot of common grounds for harmonization.
Japan indicated that a complete harmonization with EU is not acceptable for them.
Document EPPR-04-010e (EC), page 46 - 53
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EC explained their view on OBD, current draft EU regulation and idea for a GTR:
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Functional requirements have to ensure access to standardised on-board diagnostic information as a
first step in successful repair of vehicle.
On-board diagnostic information is closely related to requirements with regard to access to repair
and maintenance information.
For EU regulation, requirements are split into:
 OBD environmental test requirements (refer to test type VIII)
 Functional OBD requirements, based on UNECE R83 Rev. 4, Chapter 11. This contains both
OBD stage I and II requirements:
 OBD Stage I:
 Monitors for any electric circuit continuity failure, shorted electric circuits or
rationality failure of the emissions control system and reports those failures
which results in the OBD emission thresholds being exceeded;
 Reports the triggering of any operating mode which significantly reduces
engine torque.
 OBD Stage II:
 More advanced form of OBD operating in addition to OBD stage I;
 Monitors and reports emissions control system failures and degradation
which results in the OBD emission thresholds as laid down in part B (2) of
Annex VI being exceeded.
Pending the outcome and cost – benefit assessment from the environmental study in 2015-2016,
OBD stage II may or may not become obligatory for (sub-)categories L3e, L5Ae, L6Ae and L7Ae in
2020.
Meanwhile a vehicle may be equipped with OBD-II system, at the choice of the manufacturer. If so,
it has to comply with the requirements set out.
Environmental part only of OBD:
 Manufacturer to proof which parts are emission relevant.
 Verification by introducing fault in system and comparing emission test results over type I
with OBD threshold limits (OTL’s).
 In case of electric failure in electric circuits (including control units) of sensors or actuators,
or in case of electronic signal rationality failures in these circuits, the malfunction indicator
shall be turned on and a diagnostic trouble code stored when exceeding the OBD emission
thresholds. The EC explained that rationality failures are only limited to very simple electric /
electronic rationality failures (vehicles equipped with electronic throttle control containing
already redundant sensors and the knock sensor (if fitted) only) and that all complex
rationality fault monitoring like the oxygen sensor signal or the intake temperature sensor
signal rationality are proposed to make part of OBD stage II only.
 Text largely carried over from UNECE R83, Chapter 11, appendix 1
Planned submission EC draft proposal gtr on OBD by the end of Oct 2013.
 Suggestion to put first priority harmonisation of functional OBD and OBD emission
verification test procedure. To be discussed if OBD emissions thresholds should be
harmonized. The latter should not be assigned high priority.
 EC is willing to introduce the proposal e.g. in a phone conference.
India asked if EC’s proposal will cover OBD stages I and II.
EC said there is no clear distinction in R83 and that an effort was made to split the UN R83 requirements into
OBD stages I (obligatory) and II (voluntary).Iit is preferred to keep this approach as a start for discussion.
IMMA asked to explain why there is no clear cut between OBD I and II.
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6 a.
Proposals for amended GTR 2 (Test type I, II and VII)
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As in introduction the Chair explained that we are now focusing on EVAP and OBD, and detailed discussions
on an amendment to GTR2 can take place after progress on OBD and EVAP is made.
document EPPR-04-010e(EC), page 17-39
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EC said they went back to the roots, to CARB. CARB explained to the EC that there was no clear cut between
OBD stages I and II in history for passenger cars.
Japan asked how to deal with functional safety.
EC’s idea is to have a fault stored whenever there is a torque reduction induced by the system and
suggested to reflect on ISO 26262 , in the longer term to expand this concept in OBD.
IMMA asked stakeholders view on the 3 points of difference between Japan and EU, (rationality, RMI and
OTLs).
EC said there should be no conflict for RMI, as this part is clearly split. And OTL’s are not the highest priority
for EC), because there are different emission limits.
EC suggested to discuss OTL’s when worldwide harmonized emission limits are established.
And with regards to rationality fault diagnostic, EC said there are different types. It was suggest to discuss
the ‘simple’ types of this kind of OBD.
Japan asked if these ‘simple’ types of rationality will be added in the draft proposal for GTR. EC confirmed.
Japan suggested to meet with a small group of OBD experts before the next EPPR meeting.
IMMA offered to host the meeting in their office (max. 15 people) in Geneva on 7 Jan 2014 PM, the day
before the 5th EPPR meeting.
This appointment was tentatively set, to be confirmed soon.
EC explained the background of Regulation (EU) No 168/2013, REPPR with regards to Type I, II, V and VII:
(Type V was put in brackets because the group did no decide yet if it should be an amendment to GTR2 or if
it should be a new, dedicated separate GTR.)
For Type I, EC explained that requirements are based on GTR2, Multi-Directive 97/24/EC, chapter 5 and
amendments, UN R40, UN R47, UN R83 and UN R101. For reference fuels, whenever passenger cars move to
E10, L-category may follow in due course. For now E5 specifications were derived from UN R83 and were
proposed to be the reference fuel for vehicle equipped with PI engines.
Regarding Type II, India asked the EC to explain the benefit of the increased idle test.
EC said this is mainly relevant for vehicles with advanced fuel control. The Low-high idle test makes it clear
that there is an operating closed loop fuel control. Also lambda would be measured in that case.
Japan asked if the high idle test is really necessary. EC replied it is makes sense to take another load point to
judge the closed loop fuel control.
Japan said currently only low idle is tested for domestic Periodical Technical Inspection (PTI). The subject
needs to be discussed with the colleagues responsible for PTI.
For Type V (durability) EC explained the 3 methods available in EU regulation, and the 2 distance
accumulation method options (AMA and SRC-LeCV). EC did a study for the latter, published on their website1.
As a first step for world-wide harmonization, including both distance accumulation pattern options would be
acceptable to EC.
http://ec.europa.eu/enterprise/sectors/automotive/files/projects/report-trl-ppr627_en.pdf
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6 d.
India asked if thermal shock temperatures are the same for Compressed Iginition (CI) engines. EC
replied they mainly looked at Positive Ignition, and that surely temperatures for CI are much lower
but similar mechanisms are also to be verified for CI engines.
India said that a different test bench cycle for CI engine exists in 83, and asked if we would consider
this for the EPPR work.
o Looking at slide no. 31 (SRC-LeCV driving profile), India asked why speeds were so high.
EC replied this is optimized for vehicles that can achieve high speed, and that the profile for lower
speed vehicles is rescaled, resulting in 4 different profiles.
o India asked if the SRC-LeCV cycles are appropriate for whole L-cat range, and if acceleration rates
are not too steep.
o EC said the acceleration rates are based on WMTC, and for lower powered vehicles lower
acceleration rates apply.
o India asked if payload was considered and how this is foreseen in the definitions
EC replied that starting point was no payload.
For Type I, EC explained that requirements are based on the base GTR No 2, UN R83 and UN R101, customtailored for L-category vehicles.
Planned submission draft proposal EC gtr test types I, II, [V], VII: Nov 2013
If EPPR group would decide to dedicate a separate gtr on test type V, than this could only be compiled and
submitted in Jan 2014.
The Chair noted that anyway priority for discussion will be EVAP and OBD certainly until January.
In general, beyond the Euro 5 step EC aims at replacing EU environmental requirements to the maximum
extent possible with references to world-harmonised UN Regulations, coherent with global technical
regulations in the area of EPPR . Target is to optimise coherency with existing / near future UN legislative
requirements for other vehicle types and categories (light-duty motor vehicles).
EC’s first priority for medium term is to harmonise measurement equipment and test procedures. Long term
priority (if medium term harmonisation successful) is developing and harmonising other requirements such
as off-cycle emission test procedures, converging environmental limits etc.
To a question from India, EC confirmed that hybrid vehicles are also to be covered for Type I.
Japan said that for Hybrids and Electric Vehicles, the EVE informal group is seeking what kind of GTR is
needed.
The Chair confirmed that EVE could give us only guidance. And that it is our task (EPPR) is to make
requirements / a GTR.
Japan explained that EVE is making reference guide and suggestion the chair to discuss with the EVE chair
whether a new GTR should be made, etc.
Other proposals
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document EPPR-04-010e (EC), page 54-58
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EC explained about Annex No XII of EU REPPR, propulsion family concept. The objective is to select criteria
for a representative parent vehicle in order to demonstrate environmental performance by conducting test
types I to VIII.
EC also introduced EU requirement on propulsion unit performance test procedures, also part of REPPR.
requirements (REPPR) Max Power/Torque:
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Testing procedures and technical requirements regarding maximum design vehicle speed, maximum
torque and maximum propulsion power.
Based on EU Directive 95/1/EC, UN R85 (for determination of maximum continuous rated power of
pure electric propulsion)
Issue: propulsion performance of hybrid-electric propelled vehicles and alternative propulsions
Planned submission draft proposal EC gtr propulsion performance: Feb 2014
Roadmap and project planning
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document EPPR-04-11e (India)
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India explained their revised proposal for structure of GTR’s and ECE R’s.
o The presentation document is a revision of reference doc – EPPR-03-02e
o After further consideration, India now realizes that Contracting Parties who signed a UNECE
regulation, have to apply it to all categories mentioned in that regulation.
This might create difficulties for some CP's who are interested in applying regulations to only some
categories but not all categories covered in the scope of the regulation.
o As such India proposed creating separate UNECE regulations for 2- and 3-wheelers.
EC said they are ok with the proposal, as it is a practical way forward. EC noted that we need to take care of
cross reference between regulations.
India also suggested that proper attention needs to be given to segregate L6 and L7 category vehicles from
current low powered class-1 light duty four wheeled vehicles classified in WLTP draft GTR
India proposes formulation of appropriate test cycles for various L- category vehicles. India added that the
current WMTC cycle is based on data for motorcycles (L3 category) and that similarly, data would be
required for other L-category vehicles to formulate the respective test cycles or at least to do a validation
exercise.
India asked EC about the data on L3 and other vehicles that was mentioned at previous meeting.
EC said they have data available, but it has to be retrieved and be put in a presentable form. EC noted the
data is not to the extend as it was for the development of GTR2.
The proposal from India to create a separate GTR for durability was briefly discussed. Conclusion was that
there is no final agreement on it, and that we will come back later to it, after discussion on EVAP and OBD,
and when the proposals from EC are available. That proposal might be separated from an amendment to
GTR2.
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India suggested considering how to make amendments in the future when making final decisions.
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The Chair suggested to endorse a mechanism, like e.g. in HDH informal group, i.e. when an amendment is
made to the GTR Nos 4 and 5, always mirror amendments to UN R49 was made.
Document EPPR-04-05 (chair), page 6
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The chair explained that the target is to have a mature draft for EVAP and OBD for L3/L1 by March 2014, and
if desired an informal document can be made available for GRPE in June 2014.
With regards to an amendment to GTR2, the Chair suggested to have an initial discussion when the proposal
by EC is available, and come back on it and decide on a target date for finalization.
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Next meetings
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9.
Based on the discussion today the Chair will revise the slide with the draft roadmap on page 6.
To a question by IMMA, the chair confirmed this would be presented at the next WP29, with some
additional details so that the document can be used for presentation at both WP29 and GRPE.
5th EPPR meeting will take place 8 Jan 2014, PM in Geneva, in conjunction with the GRPE-68.
The chair suggested considering a discussion before EPPR-05: one for EVAP, one for OBD.
It was tentatively proposed to have an audio-web conference for EVAP in December 2013. Date will follow.
It was tentatively set (to be confirmed) to have an OBD expert meeting (face-to-face) on 7 Jan PM, in
Geneva at IMMA office.
For a 6th EPPR meeting, the chair suggested to have it late February in Brussels or Japan.
Japan is willing to host the meeting around February or early March.
IMMA requested to have the meeting in between 21 Feb and 10 Mar.
The Chair suggested scheduling a 3-day meeting.
Japan suggested that in the February 14 meeting also an expert meeting is needed. The Chair agreed and
noted that an HDH expert group used to meet the two days before the full meeting, e.g. for drafting. (note:
HDH is another working group under GRPE.)
7th EPPR meeting will be in June 2014, in Geneva, in conjunction with the GRPE-69
8th EPPR-08 would be organized in autumn. EC is willing to host that meeting in Brussels.
Summary and conclusions
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The proposal by EC on EVAP was initially discussed. End of November 2013 was set as target date for
comments.
The OBD proposal by EC is expected to be issued soon. Japan already provided initial comments based on
the OBD text in the draft EU regulation (REPPR/RVCR).
L1and L3 vehicles will have first priority; 3-wheel vehicles will be included in a later stage.
The heading of the draft documents will already include 3-wheel vehicles as a placeholder with the intention
to amend the documents later.
Target is to have a proposal on both EVAP and OBD by March-April 2014, in order to be in line with the
Japanese domestic regulatory process. This will provide also the opportunity to submit documents to GRPE
June 2014, if this is the wish of the group. Or to keep documents for L1 and L3 aside and amend them later.
Some issues with respect to amendment of GTR2 were discussed. In a first step a proposal on Type I, II and
VII may or may not be separated from a proposal on durability requirements, to be further discussed after
the proposals from the EC have been made available. Durability is not the first priority. It can be decided
later if a separate GTR for durability is kept, or if it is integrated in GTR2.
Regarding structure of regulations, a revised proposal was presented by India. For the UN regulations, there
are strong arguments to have separate regulations based on categorization and number of wheels, however
there also some counter arguments. No final decision was taken.
The Chair suggested to consider a mechanism in order to make our structure future proof, in order to ensure
that when amendments are made, it is done in a traceable way.
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