light duty electric and hybrid vehicles

Light duty electric and hybrid vehicles Lot 2: Emissions of road vehicles

Client: Report to European Commission - DG Enterprise and Industry

September 2013

Funded by:

Light duty electric and hybrid vehicles Lot 2: Emissions of road vehicles

Client: Report to European Commission - DG Enterprise and Industry TRL Ecorys September 2013 This document has been prepared for the European Commission however it reflects the views only of the authors, and the Commission cannot be held responsible for any use which may be made of the information contained therein.

About Ecorys and TRL

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KVER/MD TR20800rep

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Light duty electric and hybrid vehicles

Table of contents

Management summary 7

1 Introduction 13 1.1 Aims and objectives 13 1.2 Background 13 1.3 Scope of study and technology classifications 13 1.4 Project approach and structure of report 15

2 Light passenger and commercial vehicles (M1 and N1): Review of existing and future legislation, Regulations and standards 17

2.1 Current European type-approval legislation 17 2.2 Development of a Global Technical Regulation 29 2.3 Electric Vehicles and the Environment Informal Working Group (EVE-IWG) 38 2.4 Other international legislation 42 2.5 Summary 42

3 Two or three wheeled motor vehicles (L-category): Review of existing and legislation and regulations under development 45

3.1 Current European type-approval legislation 46 3.2 Legislation under development 55 3.3 Future legislation 64 3.4 Summary 66

4 Heavy duty passenger and commercial vehicles (M2+ and N2+): Review of existing legislation, Regulations and standards 69

4.1 EV & HEV Technologies 69 4.2 Recent regulatory developments 70 4.3 Summary 72

5 Review of stakeholder requirements 73 5.1 Introduction 73 5.2 How consumers choose vehicles 73 5.3 Consumer preferences based on literature 77 5.4 Stakeholders input: workshops and interviews 83 5.5 Results from consumers’ survey 87 5.6 Summary 91

6 Summary, discussion and conclusions 93 6.1 Summary of type-approval legislation and developments 93 6.2 Review of stakeholder requirements 95 6.3 Discussion 95 6.4 Conclusions 98

References 101

Glossary 105

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Overview L-category vehicles 109 Annex A

Application of test requirements for type-approval and extensions in Regulation Annex B(EC) No. 692/2008 for M1 and N1 vehicles 111

Application of test requirements for type-approval and extensions in Regulation Annex C(EC) No. 168/2013 for L category vehicles 113

Summary table of current legislative tests and measurement parameters 114 Annex D

WLTC for Class 3 vehicles 119 Annex E

Car labelling 123 Annex F

Consumers’ survey 128 Annex G

Stakeholder reactions 133 Annex H

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Management summary

Introduction The purpose of this scoping study, instigated by the European Commission, is to support and help inform any future revisions of specific type approval test procedures related to emissions and the environmental utility of Electric Vehicles (EVs) and Hybrid Electric Vehicles (HEVs). The objective of the project was to identify tests to be performed and the parameters to be measured with regard to the type approval of light duty electric and hybrid vehicles (EVs and HEVs respectively). The structure of this project was based on three elements: • A review of the existing and proposed type-approval legislation on vehicle emissions. It covered

light passenger and commercial vehicles, powered two- or three-wheel vehicles and quadricycles. Recent UNECE developments regarding heavy duty hybrid vehicles were also reviewed.

• A review of stakeholder requirements on type-approval parameters. This step comprised a stakeholder consultation in the automotive industry, users and other relevant interest groups.

• A summary, discussion and conclusions based on the previous two elements. Review of existing legislation, proposals and regulatory developments (summary) • The European type-approval regulations for M1 and N1 vehicles are covered by Regulations

(EC) 715/2007 and 692/2008. There are six main tests to control the emissions:

- Type 1 test: Verifying the average exhaust emissions at ambient conditions; - Type 2 test: Measuring carbon monoxide at idling speeds; - Type 3 test: Verifying emissions of crankcase gases; - Type 4 test: Determination of evaporative emissions; - Type 5 test: Verifying the durability of pollution control devices; - Type 6 test: Verifying the average emissions at low average temperatures.

• Regulation (EC) No. 692/2008 also specifies a test for the measurement of carbon dioxide

emissions and fuel/energy consumption and a test for electric range.

• Currently the NEDC (New European Driving Cycle) is used. However, work is currently progressing on developing a World harmonised test cycle (WLTC) and test procedure (WLTP). This should provide results more representative of real-world driving than the current test.

• Mopeds, motorcycles, tricycles and quadricycles are classified as L-category vehicles according to Directive 2002/24/EC and UN R.E.3. Currently, Directive 97/24/EC and its subsequent amendments specify the emissions related type approval regulations in Europe. However, these regulations are currently in the process of being repealed and replaced with a new “split level approach” regulatory package.

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• As per light-duty vehicles, various tests are (or are proposed to be) used to control the emissions from L-category vehicles. These also include tests to measure CO2 emissions and fuel/energy consumption.

• As part of the World Harmonisation process, a realistic test cycle for L-category vehicle has now been developed – the WMTC cycle. This has already been incorporated within UN Global Technical Regulation (GTR) No 2. In the current draft of the relevant delegated act, it is proposed that this cycle will be used in future EU type-approval test procedures.

• An Informal Group on Heavy Duty Hybrids (HDH) was established by GRPE as part of the UNECE regulatory development process in 2010. This Informal Group’s work is on-going. It is currently working towards drafting an amendment to Global Technical Regulation No. 4 for adoption by GRPE and WP.29 in 2014.

• The first draft of that amendment was published in May 2013, introducing a new Annex 8 and allowing for both a Hardware-in-the-Loop Simulation (HILS) procedure (based on existing Japanese legislation but modified in the light of the research findings) and, as an alternative, a powertrain procedure (based on the US-EPA procedure).

Review of stakeholder requirements (summary) • A wide range of stakeholders were consulted to collect opinions on the parameters that should

be standardised in type-approval. Additional consultation would give stakeholders the opportunity to comment further on the specific parameters identified by this project.

• With regard to the technical parameters four main theme resulted from the stakeholder analysis:

- The (driving) range / performance under different conditions: - Battery capabilities: - CO2-emissions / energy consumption: - Charging time of battery:

• The stakeholders want good information about the performance of EV and HEV vehicles in

different weather conditions, in different types of trips and at a different age of the battery.

• Although outside the scope of type-approval, financial and user parameters of EVs and HEVs are very important for stakeholders. On aspects like the purchase and the fuel price, the fiscal regime, the resale value, costs per km, recharging facilities and safety are all desirable information for consumers.

Discussion (summary) This section pulls together the findings from both the legislative reviews and the stakeholder requirements work, to assess the extent to which current type approval arrangements, or those already under development, are likely to generate information of value to consumers and other stakeholders. Specifically this includes reference to: • Pollutant emissions; • Electricity and fuel consumption / CO2 emissions; • Electric range; • Battery charging time in different atmospheric conditions; • Durability of batteries (charging cycles). Each of these specific issues is discussed in turn.

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Pollutant emissions While this topic did not feature in the parameters likely to be of importance to consumers, it is naturally a subject of considerable interest to many, not least regulatory authorities, health professionals and city governments. It has long been a key focus for type-approval requirements, and this focus looks set to continue. For cars and vans (M1 and N1), considerable regulatory progress has already been made over recent years, with Euro 5 requirements already in place and Euro 6 taking effect from 1 September 2014. As well as moves to introduce more representative drive cycles, discussions are also taking place within UNECE for further enhancements, e.g. to cover particulate mass and number, and to cover a wider range of pollutants. For L-category vehicles, existing requirements are some way behind (at Euro 2/3), but a legislative roadmap is being introduced to move in a series of planned steps to full Euro 5 compliance by 2020-21. It thus appears, from the evidence gathered for this study, that the tests and parameters needed to address the topic of pollutant emissions are already well covered by existing type approval arrangements, or will be by legislation already at an advanced stage of implementation. Electricity and fuel consumption / CO2 emissions The evidence gathered for this study suggests that the public at large are largely uninterested in the environmental impacts of vehicles, including CO2. Presumably for personal economic reasons, consumers seem to be somewhat more interested in a vehicle’s energy consumption (fuel and/or electricity), and this interest extends to the performance under a wide variety of conditions (e.g. weather, gradients, journey type). For the minority of consumers who are concerned about CO2 emissions, it seems that they would prefer test parameters/information pertaining to the big picture, i.e. well-to-wheel or even full lifecycle analysis data, rather than just direct emissions at the tailpipe. These issues have clear potential implications for future type approval arrangements. Existing legislation, and that under development or discussion, focuses purely on tailpipe emissions. A variety of approaches to allocating upstream fuel/energy production emissions already exist, as do life cycle analysis methodologies. Integrating these approaches into type approval legislation in a fair, realistic and straightforward way will, this study suggests, be key future challenges. On the topic of in-use fuel/electricity consumption, recent and on-going legislative developments have taken some important steps. For M1 and N1 vehicles, test provisions now exist to measure fuel/energy consumption for all forms of EVs and HEVs. Further planned refinements to the driving cycle will likely make these parameters more representative of (some) real-world conditions. Discussions are also underway within UNECE aimed at addressing the issue of fuel/energy consumption in a range of different conditions, e.g. under conditions of very hot or cold weather (with the air-conditioning or cabin heater in operation) or driving in hilly terrain. For L-Category vehicles, the proposals forming part of the development of the delegated acts include provisions for fuel/energy consumption measurement and CO2 emissions (in use). Given the more limited range of conditions under which such vehicles tend to be used (as compared to cars and vans), and the obvious lack of ancillary loads like heaters or air-conditioning systems for many such vehicles without an enclosed driver/rider cabin, there is less pressure to consider the effects of widely varying weather conditions.

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Electric range Range seems from the stakeholder evidence gathered to be an important subject in the minds of consumers and other stakeholders. For pure EVs, the reporting of “range” is quite straightforward for consumers to understand, at least under standardised driving conditions without the use of heaters or air-conditioning. Provisions exist or are in the process of being implemented for this type of measurement of “range”. HEVs, however, present a much more complex situation. To some extent, the concept of “range” for such vehicles is less significant, because they can be re-fuelled quickly and easily just like conventional ICE vehicles. Measuring and reporting a range, though, is complicated by how the battery and fuel systems work together, as well as by the effects of weather, gradient, ancillary systems, etc, (which are also relevant to EVs). UNECE developments are attempting to address these issues by defining various different types of “range”. The stakeholder review evidence suggests that consumers, however, value simplicity and metrics that relate to their anticipated usage patterns, so another key challenge for future type-approval testing and reporting is to develop range-related metrics that consumers can readily understand and use. Battery charging time in different atmospheric conditions Owners/users of EVs and (P)HEVs will, the stakeholder review suggests, be interested in how long it takes to charge the battery, both under “standard” charging conditions (akin to overnight charging at home) and “fast” charging (e.g. when they need a rapid energy boost to continue or complete their journey). They particularly want to know how these vary with weather conditions and as the battery itself gets older. These battery and charging-system performance issues are not currently addressed by type approval legislative tests, nor by planned future developments. Work underway in UNECE aims to address some of them, e.g. the effects of different charger efficiencies on charge time, but, generally speaking, they look set to remain largely un-regulated. Another key challenge, therefore, is to identify means by which charge time, and how it varies, can be tested and reported. It is likely that the basic elements for such testing are already in place, or will be introduced, for M1 and N1 category vehicles, e.g. testing at extreme temperatures and durability testing. Incorporating some measures of charge time and/or how that time varies as temperature changes or the vehicle mileage increases could thus be fairly straightforward. The testing methods currently being implemented for L-category vehicles, however, will not cover the required parameters to assess performance in extreme (hot and/or cold) atmospheric conditions. If usage of these vehicles changes in the future and consumers indicate a need for such information, testing in line with that for M1 and N1 category vehicles may also be needed. Durability of batteries (charging cycles) The stakeholder review highlighted “lifetime of the battery” as a very important issue. Range depletion (reduced range as the battery deteriorates) and efficiency loss (more KWh needed to drive the same journey as the battery deteriorates) are also related areas (parameters) of concern. As with the battery charging time issue above, existing and planned type-approval requirements do not address battery durability issues. However, and again as with charge time, the basic building

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blocks for such testing probably exist or are already under development. Durability testing, for example, could quite readily incorporate assessments of range depletion and efficiency loss (though would need to be extended to pure EVs as well as HEVs), and those could be combined to indicate a likely battery lifetime (i.e. the mileage and/or number of charge cycles after which the battery performance is likely to have deteriorated to unacceptably low levels). A final key challenge, however, may well be to ensure that simulated/accelerated durability testing is realistically correlated to real-world usage conditions for batteries (in a similar way to that already implemented for pollution control devices). Conclusions • In the case of the hybrids / electric vehicles, current standardised test procedures are still

mostly based on procedures for the conventionally fuelled vehicles. These do not always fully address the particular characteristics and risks of (P)HEVs and EVs.

• Various types of information are regulated through type-approval legislation, but many new types of information with respect to HEVs and EVs are to date not regulated. In particular the battery performance of (P)HEVs and EVs is not tested under many different conditions.

• This means that this information is not always provided to consumers or that manufacturers may use different test procedures and apply different test/laboratory conditions, resulting in different estimates and potentially confusing consumers.

• Stakeholders, in general are keen for more information to be made available, and for it to be standardised. There is a genuine desire and requirement to be able to compare like-with-like parameters, rather than have different non-standardised measures or no information at all.

• As light duty electric and hybrid vehicles become more commonplace and their technologies mature, international harmonisation of the tests to be performed and the parameters to be measured with regard to their type approval will develop; and the feedback from the stakeholder review undertaken as part of this programme will continue to have relevance. A good example of where the stakeholders believe there is potential to improve future regulation is the performance of the battery (the range/ performance of the vehicle) under a wider range of operating conditions.

• The study has identified several key likely future challenges in further developing and enhancing type-approval tests and measurement parameters for light duty EVs and HEVs. These can be summarised as: - Integrating upstream fuel/energy production emissions and life cycle analysis methodologies

into type approval legislation in a fair, realistic and straightforward way. - Developing range-related metrics that consumers can readily understand and use. - Identifying means by which charge time, and how it varies, can be tested and reported. - Ensuring that simulated/accelerated durability testing is realistically correlated to real-world

usage conditions for batteries.

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1 Introduction

1.1 Aims and objectives

The purpose of this scoping study, instigated by the European Commission, was to support and help inform any future revisions of specific type approval test procedures related to emissions and the environmental utility of Electric Vehicles (EVs) and Hybrid Electric Vehicles (HEVs). The objective of the project was to identify tests to be performed and the parameters to be measured with regard to the type approval of light duty electric and hybrid vehicles (EVs and HEVs respectively). Specifically this includes reference to: • Pollutant emissions; • Electricity and fuel consumption / CO2 emissions; • Electric range; • Battery charging time in different atmospheric conditions; • Durability of batteries (charging cycles). Vehicle noise, life-cycle analysis and any form of energy/fuel production analysis (i.e. well-to-wheel) are not covered in this report.

1.2 Background

Environmental and safety standards are widely acknowledged to be very effective for emerging markets, such as the EVs and HEVs, not only because they ensure the environmental sustainability, the public safety and maintain compatibility between jurisdictions, but also because of enhancing the speed of uptake of the new technologies and the smoothness of the transition to them (Brown et al., 2010). Standardised test procedures may result in more reliable and comparable environmental utility parameters on which consumer information can be based. Consumer uncertainties, such as range anxiety, when purchasing an EV/HEV, might be reduced by providing parameters based on standardised procedures.

1.3 Scope of study and technology classifications

In order to define the potential future tests and parameters to be measured, it is first necessary to have a good understanding of the existing type-approval processes and procedures and alternative standard tests. These are examined for three vehicle categories1: M1, N1 and L1-7, and for specific fuel / charging types, namely; hybrid, plug-in hybrid and pure electric. These last types are classified based on the recharging need and engine type; The figures at the next page provide an overview of these for M1, N1 and L category respectively.

1 Definition of the vehicles types: M1 stands for the vehicles used for the carriage of passengers comprising no more than eight seats in addition to the driver seat, N1 stands for the carriage of goods having a maximum mass not exceeding 3.5 tonnes and L stands for a wide range of light vehicles such as powered cycles, two- or three-wheel mopeds, motorcycles with and without sidecars, tricycles and quadricycles.

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Figure 1.1 Alternative technologies classification. M1 and N1 category

Figure 1.2 Alternative technologies classification. L category

The landscape of powertrains for all technologies is very broad, as outlined in the figure below, which shows the distribution of vehicles regarding the range they can travel with conventional and alternative fuels. The left-hand side represents the all-conventional vehicles (internal combustion engine/ ICE), while the right-hand side introduces the electric engines2. The electric vehicles (EVs) are solely powered by an electric powertrain. The plug-in hybrid electric vehicles (PHEVs) combine a conventional powertrain (ICE) with some sort of electric propulsion.

2 The definition of HEVs and Range extenders is also provided from the ACEA Workshop (2011).

MildHybrid (e.g. 1st and 2nd generation

Toyota Prius)

Conven-tional

FullHybrid (e.g.

3rd generation

Toyota Prius)

Plug-in hybrid (e.g. Volvo V60

plug-in hybrid, Toyota

Prius plug-in hybrid)

Range Extender (e.g. Opel Ampera, Chevrolet

Volt)

Pure electric

(e.g. Nissan Leaf,

Mitsubishi iMiEV,

Peugeot Ion, Tesla Roadster)

Internal combustion engine (ICE)

Electric motor

No recharging Increasing recharging required

Human

Electric ICE

Bicycle Not type-approved

Pedelec (Electric/Human hybrid)

Moped (Original definition: motor-pedal)

Pure electric (E-bike) HEV

Conventional

More recharging required No recharging required

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Figure 1.3 Landscape of powertrain configuration (Source: ACEA Workshop, 2011)

1.4 Project approach and structure of report

The focus of this study was to analyse the applicable parameters with regard to Type Approval legislation, specifically: • The parameters measured; • The parameters presented to the purchaser (some parameters are measured but not

presented). EV and HEV include hybrid and electric vehicles using a combination of; conventional engines, electric motors and current battery technologies. The study covers full electric and conventional engine based hybrid vehicles (all kinds, including PHEV and range extenders). Batteries are the only form of energy storage considered. However, where relevant, some alternative energy storage and propulsion methods have been assessed in much the same way, in which case parallels can be drawn by the reader to allow a wider use of the analysis performed. Another important distinction to be made is the different implementation of these technologies within the L, M1 and N1 categories. The L category has had production pure electric vehicles for some time, especially in the lighter varieties, and with the move to hybrid vehicles in the heavier tricycle and quadricycles sub categories in line with cars. The larger space and weight of M1 and N1 vehicles has driven the market towards more complex, but larger range technologies, which has in turn slowed its advancement. The structure of this project is based on three elements: • A review of the existing type-approval legislation on vehicle emissions. It covers light

passenger and commercial vehicles and powered two- or three-wheel vehicles and quadricycles. Recent UNECE developments regarding heavy duty hybrid vehicles are also reviewed.

• A review of stakeholder requirements. This step comprises a stakeholder consultation in the automotive industry, users and other relevant interest groups. Views are collected with respect

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to already regulated utility parameters, any new parameters that may be regulated in the future and the importance of providing information on environmental utility parameters to consumers.

• A summary, discussion and conclusions based on the previous two elements. Chapters 2 and 3 review the existing legislation for M1/ N1 and L category vehicles respectively, to identify the current situation. Chapter 4 reviews the technologies and recent UNECE legislative developments for heavy-duty vehicles. Chapter 5 analyses the parameters from the industries and consumers’ perspective. Chapter 6 provides a summary, discussion and conclusions. The annexes provide more detail on the various different topics3.

3 Please note that when ‘costs’ are announced in this report these refer to ‘prices’ to be paid, not to net costs for the society.

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2 Light passenger and commercial vehicles (M1 and N1): Review of existing and future legislation, Regulations and standards

This section reviews the legislation for light passenger and commercial vehicles. These are classified as Category M1 and Category N1 vehicles by Directive 2007/46/EC (as amended): Category M1: Vehicles designed and constructed for the carriage of passengers and comprising no more than eight seats in addition to the driver’s seat. Category N1: Vehicles designed and constructed for the carriage of goods and having a maximum mass not exceeding 3.5 tonnes. The main focus was the European type-approval legislation for the environmental performance of vehicles. This is summarised in Subsection 2.1, which sets out the main tests and measurement parameters. The development of a Global Technical Regulation on worldwide harmonised light-vehicle test procedures is summarised in Subsection 2.2. Subsection 2.3 reviews the work of the UNECE Electric Vehicles and the Environment Informal Working Group (EVE-IWG). Other international legislation is compared in Subsection 2.4. A brief summary is provided in Subsection 2.5.

2.1 Current European type-approval legislation

Overview European Union (EU) type-approval of light passenger and commercial vehicles with respect to their emissions is set out in Regulation (EC) No. 715/2007 and Commission Regulation (EC) No. 692/2008. These Regulations are part of a new regulatory approach that has been introduced into European Community vehicle legislation (and is sometimes called the “split-level approach”). In line with this new approach, Regulation (EC) No. 715/2007 contains the fundamental provisions on vehicle emissions laid down by the European Parliament and the Council. The technical specifications (known as the “implementing measures”) are set out in Commission Regulation (EC) No. 692/2008. These Regulations repeal and replace Directive 70/220/EEC (on light duty emissions) and Directive 80/1268/EEC (on the measurement of CO2 emissions), and all of their amending directives. Sixteen European Community directives are repealed and replaced in total. The regulations have been subsequently amended by: • Regulation (EC) No 595/2009, • Commission Regulation (EU) No 566/2011 and • Commission Regulation (EU) No 459/2012. Regulation (EC) No. 715/2007 introduces new emissions limits and makes additional requirements on access to vehicle repair and maintenance information. These new limits take effect in two stages; Euro 5 starting from 1 September 2009 and Euro 6 from 1 September 2014. Regulation (EC) No. 692/2008 (as amended) specifies more detailed technical requirements for type-approval and extensions, and for in-service conformity. It also specifies a series of tests according to the engine type and fuel. The application of the tests for type-approval and extensions is shown in

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Annex B. Regulation (EC) No. 692/2008 (as amended) generally refers to UN Regulations for the test procedures and for some of the technical requirements, but also sets out certain exceptions. The figure below provides an overview of the type-approval legislation for emissions from light passenger and commercial vehicles. Figure 2.1: Overview of the type-approval legislation for vehicle emissions

Burning fuel in a combustion engine produces various by-products, which are released through the exhaust system or through fuel evaporation. There are six main tests in Regulation (EC) No. 692/2008 (as amended), which seek to control these emissions directly: • Type 1 test: Verifying the average exhaust emissions at ambient conditions; • Type 2 test: Measuring carbon monoxide at idling speeds; • Type 3 test: Verifying emissions of crankcase gases; • Type 4 test: Determination of evaporative emissions; • Type 5 test: Verifying the durability of pollution control devices; • Type 6 test: Verifying the average emissions at low average temperatures. There are a further two tests that are also relevant to the control of pollution: • On-board diagnostic test (Referred to as type 8 test in UN R83 and L-category legislation); • Smoke opacity test, applicable to compression ignition (CI) vehicles only (This test is grouped

with the Type 2 test within UN R83 and L-category legislation). Regulation (EC) No. 692/2008 (as amended) also specifies a test for the measurement of carbon dioxide emissions and fuel/energy consumption and a test for electric range (Referred to as type 7 test in L-category legislation). Each of these tests and the main parameters that are currently measured are reviewed in the remainder of this subsection. Type 1 test: Verifying average exhaust emissions at ambient conditions Exhaust emissions occur during two main phases: cold-start emissions and running emissions. Cold-start emissions occur when a vehicle is started and can continue for the first few minutes of driving. They are typically greater than running emissions because the exhaust after-treatment system has not reached its normal (optimum) operating temperature. For some pollutants, a large proportion of the total emissions from road transport, especially in urban areas, is due to vehicles being driven under cold-start conditions (Boulter et al., 2009). Running emissions occur after a

Regulation (EC) 715/2007 Fundamental provisions on

vehicle emissions

Regulation (EC) 692/2008

Technical requirements for implementation

UNECE Regulation 83 (Emissions)

UNECE Regulation 101 (CO2 emissions, fuel/energy consumption and range)

UNECE Regulation 24 (Smoke opacity)

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vehicle has warmed up and the after-treatment system is fully operational. These ‘hot’ emissions usually represent the main contribution to the lifetime exhaust emissions from a vehicle. The Type 1 test evaluates a vehicle’s emissions after a cold start. It is performed under laboratory conditions with a chassis dynamometer that is adjusted to simulate the road load force that would act on the vehicle on the road. The vehicle proceeds through a pre-defined driving cycle and the exhaust gases are diluted, sampled and analysed. The main technical requirements for the test are set out in Annex III of Commission Regulation (EC) No. 692/2008 (as amended), which in turn refers to Annex 4 of UN Regulation 83. Before the main emissions test, the vehicle is put through a conditioning procedure. This includes a preconditioning phase where full or partial driving cycles are driven (depending on the type of engine) to stabilise the thermal condition of the engine, the exhaust after-treatment device, the transmission, tyres and the dynamometer bearings. The vehicle must then ‘soak’ for at least six hours at a temperature of 293-303 K (20°C-30°C), and until the engine oil temperature and coolant (if any) are within ±2 K of the room temperature. The emissions measurement is made over an operating cycle, commonly known as the New European Driving Cycle (NEDC). The cycle is made up of two parts: Part One (urban cycle) and Part Two (extra-urban cycle). In Part One, a short urban cycle (defined as the elementary urban cycle) is repeated four times, without interruption. This represents city driving conditions and is characterised by low vehicle speed, low engine speed and load and low exhaust gas temperature. This original test (without Part Two) was introduced in 1970, called the Urban Driving Cycle and also known as the ECE R15 cycle. Part Two represents a higher-speed driving style, which is performed immediately after Part One. This revised test cycle was introduced in 1990. The combined test cycle (Part One and Part Two) was known as the ECE + EUDC test cycle or as the MVEG-A cycle. Originally, the Part One cycle included a 40 second idling period at its beginning. The engine was started at time = 0 seconds, but emission sampling did not begin until time = 40 seconds. In 2000, this idling period was removed from the cycle, with emission sampling starting at key-on at time = 0 seconds. This allowed all the cold start emissions to be captured. This revised Part One and Part Two cycle is known as the New European Driving Cycle (NEDC). Both parts comprise a number of phases of idling, acceleration, steady speed, deceleration and gear change. Some general characteristics of the two parts of the driving cycle are shown Table 2.1. Figure 2.2 shows the speed plotted against time. Table 2.1 General characteristics of the NEDC driving cycle

Part 1 (Urban driving cycle) Part 2 (Extra-urban driving cycle)

Average speed during test 19 km/h 62.6 km/h

Effective running time 195 s times four 400 s

Theoretical distance covered per

cycle

1.013 km times four

(4,052 km for the four cycles)

6.955 km

Maximum speed 50 km/h 120 km/h

Maximum acceleration 1.04 m/s2 0.83 m/s2

Maximum deceleration -0.99 m/s2 -1.39 m/s2

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Figure 2.2: Graphical plot of the NEDC driving cycle

During the test, the temperature in the test cell must also be 293-303 K (20°C-30°C), and the absolute humidity of either the air in the test cell or the intake air of the engine must be 5.5-12.2 g H2O/kg dry air. These are considered ambient conditions. Sampling begins before, or at the start of, the engine start-up procedure and ends on the conclusion of Part Two of the driving cycle. The sampled emissions from the ECE (Part One) and EUDC (Part Two) parts are stored in separate bags. Owing to the higher engine load the exhaust volume is higher for the 2nd bag; this averts the dilution of the "cold start" contribution which is held within the first bag. Following the test, the exhaust gases from each bag are separately; diluted, sampled, analysed and weighted to derive the mass emissions in mg/km, for comparison with the set emission limits, for:

• Carbon monoxide; • Total hydrocarbons (positive-ignition only); • Non-methane hydrocarbons (positive-ignition only); • Oxides of nitrogen; • Combined hydrocarbons and oxides of nitrogen (compression-ignition only) In addition to gaseous emissions, the mass of particulate matter is also measured (in mg/km) for compression-ignition vehicles and also for positive-ignition vehicles fitted with direct injection engines. For these vehicles, there is now a new requirement to measure the number of particles (#/km) as well as the mass of particles. This requirement was initiated in Regulation (EC) No 715/2007, with limits introduced by Commission Regulation No 692/2008 and its subsequent amendments. These are commonly known as the ‘regulated pollutants’. The carbon dioxide concentration is also determined for use in the calculation procedure, but no limit value is defined for the individual approved vehicle, there are only fleet average limit values that have to be met by manufacturers.

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Hybrid electric vehicles must comply with the same emission limits as conventional vehicles. However, there are some differences in the way the test is carried out, and particularly in the preparation and conditioning of the vehicle. Specific provisions for hybrid vehicles are set out in Annex X of Commission Regulation (EC) No. 692/2008 (as amended), which refers to Annex 14 of UN Regulation 83. The UN Regulation defines four categories of hybrid electric vehicles, as shown in the table below, which determine how the test is carried out. Table 2.2: Categories of hybrid electric vehicles in UN Regulation 83

Vehicle charging Off-vehicle charging (OVC) Not off-vehicle charging (NOVC)

Operating mode switch Without With Without With

Hybrid vehicles featuring off-vehicle charging (also known as “externally chargeable”) are tested under two conditions (regardless of the presence of an operating mode switch4): • Condition A: Fully charged electrical energy/power storage device; • Condition B: Electrical energy/power storage device in minimum state of charge (maximum

discharge capacity). These hybrids are generally conditioned in the same way as conventional vehicles (including re-charge of the auxiliary battery during soak, see section Charging the batteries below). For example, the same preconditioning cycles are performed according to the engine type; and the vehicles are left to soak in the same temperature and for the same period. There are, however, additional procedures for hybrids for discharging the energy storage device, which vary depending on the presence of an operating mode switch and whether testing under Condition A or B. There are also specifications for charging the vehicles (when testing under Condition A). Hybrid vehicles also follow the same driving cycle as conventional vehicles. However, different gear shift points may be applied, if the vehicle employs a special gear shifting strategy (though most, but not all, hybrids have automatic transmission). In addition, in the case of Condition A, the procedure allows two approaches to be taken for the sampling period. The first is the same as that for conventional vehicles; sampling begins before, or at the start of, the engine start-up procedure and ends on the conclusion of Part Two of the driving cycle. The second option allows consecutive combined cycles to be driven until the battery reaches its minimum state of charge. Sampling ends at the end of the cycle during which the battery has reached a minimum state of charge (defined as not more than 3% discharge during the cycle, relative to nominal capacity of the battery). This is determined by measuring the electricity balance over each combined cycle and essentially by identifying the point where the battery is no longer being discharged. The first sampling approach is ideal for hybrid electric vehicles with off-vehicle charging that feature a simple control strategy. For instance, where the vehicle operates in a purely electric mode until the battery reaches its minimum state of charge and the internal combustion engine takes over. The second approach is ideal for vehicles with a more complex control strategy that allows the electric motor and the internal combustion engine to operate together. This could be during periods of high power demand, or to reduce the proportion of work from the ICE during the emission abatement parts (catalytic converter(s) and lambda sensor) warming up period. A weighted average of the emissions results from the two tests (i.e. under Condition A and Condition B) is calculated using a formula that also takes into account the vehicle’s electric range and the distance between two recharges (assumed to be 25 km). The electric range is determined

4 The procedure for externally chargeable hybrid vehicles with an operating mode switch includes a table that specifies how the switch must be positioned during the Condition A and Condition B tests.

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using the procedure in Annex 9 of UN Regulation 101. If the second option is used for sampling, the formula used to determine the weighted average of the emissions differs slightly and takes account of the “OVC range” rather than the “electric range”. The range testing procedures are described further below. Not off-vehicle charging hybrid vehicles (also known as “not externally chargeable”) are essentially tested in the same way as conventional vehicles, with relatively few additional provisions. However, they must complete at least two consecutive and complete driving cycles for preconditioning, without soak (regardless of the presence of an operating mode switch). During these cycles, and in the main emissions test, different gear shift points may be used if necessary. Not externally chargeable hybrids with an operating mode switch that are capable of several hybrid modes are tested in the mode that is automatically set after turning on the ignition key. Type 2 test: Measuring carbon monoxide emissions at idling speeds The Type 2 test measures carbon monoxide across a range of idling speeds. It applies to vehicles with positive-ignition engines only and is done for roadworthiness purposes. The carbon monoxide content of the exhaust gases is measured in percent and must fall within certain limits, to be determined by the manufacturer. The main technical requirements for the test are set out in Annex IV of Commission Regulation (EC) No. 692/2008 (as amended), which in turn refers to Annex 5 of UN Regulation 83. The test is performed with an environmental temperature of 293–303 K (20°C-30°C). Before the test, the engine is warmed up until the cooling and lubrication systems have reached temperature and pressure equilibrium, this is usually done by performing the Type 2 test soon after the Type I test. Manual or semi-automatic vehicles are tested with the gear lever in “neutral” and with the clutch engaged. Automatic vehicles are tested with the gear lever in “neutral” or “parking”. At normal engine idling speed, the maximum permissible carbon monoxide content of the exhaust gas is the value specified by the manufacturer, up to a limit of 0.3% by volume. At high idle speed (at least 2,000 rpm), the carbon monoxide content cannot exceed 0.2%. Hybrid electric vehicles (as well as conventional vehicles fitted with stop-start systems) are tested in the same way as conventional vehicles, although the manufacturer must provide a “service mode” that allows the test to be performed with the fuel consuming engine running. Type 3 test: Verifying emissions of crankcase gases Crankcase gases can include (amongst other substances) unburnt combustion gases, light hydrocarbons and oil vapours that escape into the crankcase through the piston rings. Uncontrolled crankcase emissions can have a detrimental effect on the efficiency of an internal combustion engine as well as increasing exhaust emissions. However, modern vehicles are equipped with crankcase ventilation systems that are designed to control gases out of the crankcase and feed them into the engine in which these are combusted, so-called positive crankcase ventilation. The main Type 3 test does not measure crankcase gases directly; instead, it measures the pressure in the crankcase to verify that it does not exceed atmospheric pressure (i.e. as a result of a build-up of crankcase gases). Overpressure in the system could lead to crankcase gases being evacuated directly into the environment instead of being aspired into the engine and combusted. To prevent this from happening in M and N category vehicles there is always a slight vacuum created in the crank case ventilation system to ensure zero emissions from this system. The main technical requirements for the test are set out in Annex V of Commission Regulation (EC) No. 692/2008 (as amended), which refers directly to Annex 6 of UN Regulation 83.

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This test applies to vehicles with positive-ignition engines only and is carried out after the Type 1 and Type 2 tests. The measurement is performed in three sets of conditions of engine operation, which are shown in Table 2.3. Table 2.3 Conditions of engine operation for Type 3 testing

Condition number Vehicle speed (km/h) Power absorbed by the brake

1 Idling Nil

2 50 ± 2 (in 3rd gear or “drive”) That correspond to the setting for Type 1 test at 50 km/h

3 50 ± 2 (in 3rd gear or “drive”) That for conditions No.2, multiplied by a factor of 1.7

The vehicle has met the requirements if, in every condition of measurement, the pressure in the crankcase does not exceed the atmospheric pressure at the time of the test. However, if the pressure exceeds atmospheric pressure in one of the conditions, an additional test may be performed (at the request of the manufacturer). This additional test involves fitting a bag to the dipstick hole. The bag is empty and opened to the crankcase for five minutes for each measurement condition. The vehicle is satisfactory if there is no visible inflation of the bag. Hybrid electric vehicles (as well as conventional vehicles fitted with stop-start systems) are tested in the same way as conventional vehicles, although the manufacturer must provide a “service mode” that allows the test to be performed with the fuel consuming engine running. Type 4: Determination of evaporative emissions Evaporation from petrol fuel systems makes a significant contribution to emissions of hydrocarbons from road transport (Boulter et al., 2009). These evaporative emissions can occur in three main ways (excluding refuelling): 1. Running loss: the hot engine and exhaust system can vaporise petrol while the vehicle is

running; 2. Hot soak loss: the engine remains hot for a period of time after the vehicle is turned off and

hence evaporation can continue while the vehicle is parked and cooling down; 3. Diurnal loss (while parked and engine is cool): evaporation can occur when the vehicle is

parked for long periods, if the temperature rise during the day is sufficient to heat the fuel tank. Evaporative emissions control systems have been fitted to vehicles since the 1990s to trap evaporative emissions from the fuel tank and carburettor, but only after legal requirements were introduced. A charcoal canister is typically used, which absorbs hydrocarbon molecules in the vapours and, if necessary, stores them until they can be pulled into the engine for combustion. Instead of evacuating these hydrocarbons to the atmosphere, which is a complete waste, these vapours actually participate in combustion when led back into the engine and positively contribute to the kinetic output of the engine. The Type 4 test evaluates the loss of hydrocarbons by evaporation from the fuel system of vehicles. It is performed under laboratory conditions with a chassis dynamometer in a gas-tight measuring chamber. The main test comprises three phases: test preparation (including an urban and extra-urban driving cycle); hot soak loss determination; and diurnal loss determination. The mass emissions of hydrocarbons measured during the hot soak and diurnal loss phases are added together to provide an overall result. The technical requirements for the test are set out in Annex VI of Commission Regulation (EC) No. 692/2008 (as amended), which simply refers to Annex 7 of UN Regulation 83.

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Before the main evaporative emissions test, the vehicle is prepared for testing in a test area with an ambient temperature of 293-303 K (20°C-30°C). This includes verifying the ageing of the canister and canister preconditioning. In vehicles with multiple canister systems, each canister must undergo the procedures separately. Firstly, the ageing of the canister is verified by demonstrating it has accumulated at least 3,000 km, or by removing the canister and following a procedure in the Regulation. The canister is then preconditioned by measuring the canister emissions to determine breakthrough (defined as the point at which the cumulative quantity of hydrocarbons emitted is equal to 2 grams). Two methods are provided for determining breakthrough: canister loading with repeated heat builds to breakthrough (i.e. with petrol) and butane loading to breakthrough. Alternatively, an auxiliary evaporative canister may be connected downstream of the vehicle’s canister. Within one hour of completing the canister loading (i.e. preconditioning), the vehicle is placed on a chassis dynamometer and driven through one Part One and two Part Two driving cycles of the Type 1 test. Within five minutes of completing the driving cycle, the vehicle must ‘soak’ for at least 12 hours, up to a maximum of 36 hours, at a temperature of 293-303 K (20°C-30°C). At the end of the soak, the engine oil and coolant temperature must be within ±3 K of the room temperature. After completing the soak, the vehicle is driven through a complete Type 1 test drive (one Part One and two Part Two). The engine is then shut off. Within two minutes, the vehicle is driven a through a further conditioning drive of one Part One cycle. The engine is then shut off again. The exhaust emissions may be sampled during these cycles, but they may not be used for emissions type-approval. The first evaporative emissions test is a hot soak test, carried out in a measuring chamber with a stable hydrocarbon background. The 60 ± 0.5 minute hot soak begins when the chamber is sealed. The ambient temperature of the enclosure is 296-304 K during the test. A further soak is performed (for at least six hours) following this test. The second evaporative emissions test is then carried out. This is a diurnal test in which the vehicle is exposed to one cycle of ambient temperature over a 24 hour period according to a profile specified in the Regulation. Evaporative losses from the hot soak and diurnal phases are calculated using the initial and final hydrocarbon concentrations, temperatures and pressures in the enclosure, together with the enclosure volume. The overall hydrocarbon mass emission for the vehicle is the sum of the hot soak and diurnal results. The evaporative emissions must be less than 2 grams/test. Hybrid electric vehicles are largely tested in the same way as conventional vehicles, but some additional provisions are set out in Annex X of Commission Regulation (EC) No. 692/2008 (as amended), which refers to Annex 14 of UN Regulation 83. Before starting the evaporative emissions test procedure, hybrid vehicles must undergo certain preconditioning procedures depending on their method of charging and on the presence of an operating mode switch. However, in general, hybrid vehicles featuring off-vehicle charging must undergo a procedure to discharge the electrical energy/power storage device, while not off-vehicle charging hybrids must complete additional driving cycles for preconditioning. Type 5: Verifying the durability of pollution control devices Vehicles are fitted with various exhaust gas after-treatment systems as one means of achieving better emissions performance. The durability of these systems is very important, if the performance of the vehicle is to be maintained over its lifetime (and as its mileage increases).

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The Type 5 test establishes deterioration factors that are used to ensure compliance with the emissions limits in Regulation (EC) No. 715/2007 during the useful life of the vehicle. The deterioration factors can be obtained in one of three ways: whole vehicle durability testing to 160,000 km driven on a test track, on the road or on a dynamometer; bench ageing durability testing; or as an alternative to durability testing, the manufacturer may apply assigned durability factors listed in the Regulation. The main technical requirements for the test are set out in Annex VII of Commission Regulation (EC) No. 692/2008 (as amended), which in turn refers to Annex 9 of UN Regulation 83. The whole vehicle durability test is carried out with a driving cycle that comprises 11 cycles covering 6 km each5. The overall cycle is repeated until the vehicle has driven 160,000 km. Exhaust emissions are measured at the start of the test (i.e. at 0 km), and at least every 10,000 km until the full distance is covered. The emissions measurements are made according to the Type 1 test procedure. The results are plotted against running distance and a straight line of best fit is drawn through the data points (excluding the result at 0 km. The interpolated 6,400 km and 160,000 km results must fall within the performance limits for the Type 1 test. An exhaust emission deterioration factor is then calculated for each pollutant as a ratio of the mass emissions interpolated to 6,400 km and to 160,000 km. As an alternative to the whole vehicle durability test, the manufacturer may choose to use a bench ageing durability test to determine the deterioration factors. With this approach, the vehicle is run through at least two Type 1 tests before the after-treatment system is removed from the vehicle and subjected to an ageing procedure specified in the Regulation. It is then reinstalled in the vehicle and at least two further Type 1 tests are carried out. The deterioration factors are then calculated in the same way as the whole vehicle test. The deterioration factors derived from the Type 5 test comprise part of the requirements for the Type 1 test. As an alternative to (whole vehicle or bench) durability testing, the manufacturer can choose to apply deterioration factors specified in the Regulation. Hybrid electric vehicles are generally tested in the same way as conventional vehicles. However, some additional provisions for hybrids are set out in Annex X of Commission Regulation (EC) No. 692/2008 (as amended), which refers to Annex 14 of UN Regulation 83. These are relatively minor in nature. For example, in the case of hybrid vehicles with off-vehicle charging, the Regulation states that vehicles may be charged twice a day during the mileage accumulation and may change hybrid mode if necessary. The key provision for hybrid vehicles featuring off-vehicle charging is that the emissions measurements are made according to Condition B in the Type 1 test (i.e. with the battery at the minimum state of charge). Type 6: Verifying the average emissions at low ambient temperatures Exhaust emissions are typically greater after a cold start because the oil, coolant and engine are equal or close to the ambient temperature. In general, the lower the ambient temperature, the more significant these problems are (Bielaczyc et al., 2011). The Type 6 test evaluates a vehicle’s emissions of CO and HC after a cold start in low ambient temperatures. It is performed with a chassis dynamometer adjusted to simulate the operation of a vehicle on the road at 266 K (-7°C) ambient temperature. The vehicle follows the NEDC driving cycle in a test cell maintained at this low temperature for the duration of the test. The exhaust gases are analysed for hydrocarbons, carbon monoxide, and carbon dioxide, but there are only limits for

5 A modified driving cycle is also provided in the regulation and may be used at the manufacturer’s request.

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HC and CO. The main technical requirements for the test are set out in Annex VIII of Commission Regulation (EC) No. 692/2008 (as amended), which in turn refers to Annex 8 of UN Regulation 83. The conditioning procedure includes a preconditioning drive followed by a ‘soak’ period to stabilise the vehicle before the main emissions test. Two alternative methods are provided for the soak, but essentially, the vehicle is stabilised at an average temperature of 266 K (-7°C). The main emissions sampling is performed over one Part One driving cycle. Before the test begins, the test cell temperature must be 266 K (-7°C) ± 2 K (measured in the air stream of a cooling fan that directs cooling air to the vehicle). Humidity in the test cell must be kept low enough to prevent condensation on the dynamometer rolls. The exhaust gases are diluted with ambient air and analysed for hydrocarbons, carbon monoxide and carbon dioxide. The test is performed three times and limits are applied to the emissions of carbon monoxide and hydrocarbons only (in g/km) (but as stated above, for only the first part of the NEDC test cycle). Hybrid electric vehicles are generally tested in the same way as conventional vehicles. The emissions measurements for off-vehicle charging hybrids made according to Condition B in the Type 1 test (i.e. with the battery at the minimum state of charge). On-board diagnostics test On-board diagnostic systems monitor, among others, the main emission control system and warn the driver in the event of a fault. Commission Regulation (EC) No. 692/2008 (as amended) makes their fitment to at least monitor the emission control system, mandatory for type-approval. The main requirements are set out in Annex XI (of the Regulation), which refers to Annex 11 of UN Regulation 83. The requirements cover the functional aspects of the system and include a performance test. The on-board diagnostics test is carried out on the vehicle used for the Type 5 durability test (and at the conclusion of the Type 5 test). The Regulation specifies a series of failure modes for each engine type (i.e. positive ignition or compression-ignition). After introducing one of the prescribed failure modes, the vehicle is preconditioned by driving at least two consecutive Type 1 test cycles (Parts One and Two). The main on-board diagnostics system test comprises a further Type 1 test cycle (Parts One and Two). The malfunction indicator must activate before the end of the test. Hybrid electric vehicles are generally tested in the same way as conventional vehicles. The emissions measurements for off-vehicle charging hybrids made according to Condition B in the Type 1 test (i.e. with the battery at the minimum state of charge). Smoke opacity The opacity of exhaust emissions is a measure of the degree to which the exhaust smoke blocks light. The measurement of smoke opacity is carried out on vehicles with compression-ignition engines only and is made for roadworthiness purposes. The main technical requirements are set out in Annex IV of Commission Regulation (EC) No. 692/2008 (as amended), which in turn refers to Part III of UN Regulation 24. The UN Regulation specifies two methods for measuring the emissions of “visible pollutants”. The first method determines the opacity of the exhaust gases with the engine running under full-load and at steady speed. Measurements are made between the maximum and the minimum rated speed of the engine and one point of measurement must coincide with the speed at which the

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engine develops its maximum power and the speed at which it develops maximum torque. The second method determines the opacity of the exhaust gases under free acceleration with the engine at its maximum rated speed and power. In each case, the light-absorption coefficient of the gases is measured with an opacimeter and must fall within certain limits specified in the Regulation as a function of the nominal gas flow. There are no specific type-approval test procedures for hybrid electric vehicles (diesel hybrids were rare in the M1 and N1 categories, but as they have recently been introduced by Peugeot, Citroen and Mercedes, they are likely to become more common). However, the UN Regulation specifies that if performing the tests requires a special procedure, it must be detailed in the service manual (or equivalent media). Carbon dioxide emissions and fuel/energy consumption Carbon dioxide emissions and fuel consumption are not regulated (i.e. no performance limits are applied6). However, they are measured and the results must match the values declared by the manufacturer. The main technical requirements for the test are set out in Annex XII of Commission Regulation (EC) No. 692/2008 (as amended), which in turn refers to Annex 6 of UN Regulation 101 for vehicles with an internal combustion engine only. The Type 1 exhaust emissions test procedure (i.e. Annex 4 of UN Regulation 83) is used to determine the carbon dioxide emissions and fuel consumption. The test was described earlier, but essentially, the vehicle is placed on a chassis dynamometer and is operated over a pre-defined driving cycle. The emissions of carbon dioxide and fuel consumption are determined separately for Part One (urban driving) and Part Two (extra-urban driving) of the driving cycle. The mass emission of carbon dioxide (in g/km) is measured and the fuel consumption (in litres per 100 km, for liquid fuels) is calculated from the emissions results. As noted above, there are no performance limits, but the measured values must match the values declared by the manufacturer. Specific provisions for hybrid electric vehicles are set out in Annex 8 of UN Regulation 101. These describe a method of measuring carbon dioxide emissions and determining fuel consumption and electric energy consumption. The main test procedure is practically identical to that specified for hybrid vehicles in the Type 1 emissions test (i.e. Annex 14 of UN Regulation 83) and summarised earlier in this subsection. Hybrid vehicles featuring off-vehicle charging are tested according to Condition A (fully charged) and to Condition B (minimum state of charge). The carbon dioxide emissions (in grams) are measured and fuel consumption (in litres) are determined based on CO2 and pollutant concentrations in the vehicle's tailpipe emissions. The electric energy consumption (in watt-hours) is determined from energy measurement equipment placed between the mains socket and the vehicle charger. When testing to Condition A, the vehicle is charged within 30 minutes of the end of the last driving cycle. The charge energy delivered from the mains is the electric energy consumption for this condition. When testing to Condition B, the vehicle is charged within 30 minutes of the end of the last cycle before being discharged by driving on a test track or dynamometer, etc. Within 30 minutes of this discharge, the vehicle is charged again. The electric energy consumption for this condition is the energy consumption from the first charge minus the energy consumption from the second charge.

6 Although no type-approval limits apply for each vehicle model, Regulation (EC) No. 443/2009 sets performance standards for the average carbon dioxide emissions (in g/km) for all new cars registered in the European Community that each manufacturer is responsible for. The regulation requires that by 2015, each manufacturer’s fleet average carbon dioxide emissions should not exceed 130 g/km.

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Weighted averages of the carbon dioxide emissions (in g/km), fuel consumption (in l/100 km) and energy consumption (in Wh) from the two tests (i.e. Conditions A and B) are calculated using a formula that takes into account the vehicle’s electric range (or the “OVC range”, depending on the sampling method) and the distance between two recharges. The test results for not off-vehicle charging hybrids are corrected to correspond to a zero energy balance of the vehicle’s battery. The Regulation specifies a calculation to determine correction coefficients that take account of the carbon dioxide emission or fuel consumption, the electricity balance and the number of tests. This requires a number of repeat tests on the vehicle, to cover varying charge balances. The electricity balance (in Ah) is measured according to a specified procedure and is used as a measure of the difference in the vehicle battery’s energy content at the end of the cycle compared to the beginning. Specific provisions for purely electric vehicles are set out in Annex 7 of UN Regulation 101. These describe a method of measuring electric energy consumption. The test is carried out at a temperature of 20°C-30°C. Before the main part of the test, the battery is discharged by driving the vehicle on a test track or chassis dynamometer, etc. It is then charged fully and placed on a chassis dynamometer. The vehicle is driven over the Type 1 test operating cycle comprising four elementary urban cycles and an extra-urban cycle, carried out twice. It is connected to the mains within 30 minutes of completing the operating cycle and the charge energy is measured using equipment placed between the mains socket and the vehicle charger. The electric energy consumption (in Wh/km) is calculated by dividing the charge energy by the distance covered during the dynamometer test. The value of electric energy consumption adopted as the type-approval value is the manufacturers declared value provided that the test result does not exceed the declared value by more than 4 percent. The measured value can be lower without limitations. No performance limit is applied to the electric energy consumption of electric vehicles (EVs count as zero emission vehicles for the purpose of fleet average CO2 targets). Electric range No performance limit is specified in the Regulation, but the range measured by this method must match the manufacturers declared value and is the only one that can be used in sales and promotional material. The method for measuring electric range for externally chargeable hybrid electric vehicles and for purely electric vehicles is set out in Annex 9 of UN Regulation 101. The range test comprises two main steps: an initial charge of the battery followed by the application of a driving cycle and range measurement. As part of the initial charge procedure, the battery is discharged while driving (on a test track or chassis dynamometer, etc.) until certain criteria are met, depending on the type of powertrain. The vehicle is then charged in ambient temperature of 20°C-30°C for 12 hours (unless indication is given to the driver that the vehicle is not fully charged in this period). The range measurement is made on a chassis dynamometer, also at 20°C-30°C. Purely electric vehicles are driven over consecutive cycles (Part One and Part Two of the driving cycle in figure 2.2) until the vehicle is unable to meet the target curve or when an indication from the standard on-board instrumentation is given to the driver to stop the vehicle. The vehicle is slowed down to 5 km/h without braking by releasing the accelerator pedal. It is then stopped (by braking) and the electric range is the distance covered in kilometres, rounded to the nearest whole number. The electric range of hybrid vehicles is determined largely in the same way as that for purely electric vehicles. The range is the distance travelled by the electric motor only. If a vehicle operates

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in both electric and hybrid modes during the test, periods of electric only operation are determined by measuring current to the injectors or ignition. The UN Regulation also specifies a procedure to determine the “OVC range” of hybrid vehicles. In this case, the vehicle is run through consecutive driving cycles until its minimum state of charge is reached. Driving is then continued until the end of Part Two of the driving cycle. The OVC range of the vehicle is the total distance travelled in kilometres. The electric range or OVC range are also used in the final calculation of the weighted average of the emissions results following the Type 1 test. The approach selected for the sampling period in the Type 1 test determines which range measurement is used. If the first sampling approach is taken (i.e. sampling ends on completion of Part Two of the drive cycle), the electric range is used. If the second approach is taken for the emissions test (i.e. sampling over consecutive driving cycles), the OVC range is used in the calculation. Charging the batteries The auxiliary battery – i.e. the battery used for starting a conventional engine or for powering control system in an electric vehicle – can be charged during soak periods. In UN Regulation 101, this is defined as

“All energy storage systems available for other than traction purposes (electric, hydraulic, pneumatic, etc.) shall be charged up to their maximum level specified by the manufacturer.”

This relates specifically to two of the tests: 1. Method of measuring the electric energy consumption of vehicles powered by an electric power

train only (Annex 7) 2. Method of measuring the electric range of vehicles powered by an electric power train only or by

a hybrid electric power train (Annex 9) If the test were performed with a partially discharged auxiliary battery, then some of the traction battery or energy from the engine could be used to recharge the battery leading to higher energy consumption figures and a lower range. There is no mention of charging the auxiliary battery during the other tests or in UN Regulation No 83, though it does not say it can’t be. The condition of the traction batteries is set according to the test type and vehicle type. • For electric vehicles, the batteries are charged overnight • For non OVCs hybrids, the vehicle (and battery pack) is conditioned by driving over a defined

preconditioning cycle. No external charging of the battery pack is performed during the soak. • OVC hybrids are tested under 2 conditions

- Fully charged – in which case the traction batteries are charged during the soaked - Minimum state of charge – in which case no charging is performed during the soak.

2.2 Development of a Global Technical Regulation

Overview In 2007, the World Forum for Harmonisation of Vehicle Regulations (WP.29) set up an informal group under the Working Party on Pollution and Energy (GRPE) to prepare a road map for the development of a Global Technical Regulation on worldwide harmonised light-vehicle test

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procedures. The informal group (WLTP) completed a roadmap proposal in 20097. The roadmap described three phases of work and included a schedule with milestones. It is summarised in Figure 2.3. On-board diagnostics was subsequently removed from the roadmap, to be covered by another Global Technical Regulation. In addition, some members of GRPE expressed concern about the ambitious goal of the Global Technical Regulation, given the current constraints on resources, and proposed that Phase I focussed on the driving cycle and test procedure. Figure 2.3 Three phases of work in the proposed roadmap on worldwide harmonised light-vehicle test

procedures

The roadmap was presented to WP.29 at the 148th Session in June 20098. The executive committee of the 1998 Agreement (AC.3) agreed to limit Phase I to the development of a harmonised driving cycle and to the development of a test procedure. This took account of the decision of the European Commission to apply mobile air conditioning and off-cycle emissions procedures by 2014. At the same time, work has continued, within GRPE, to develop test procedures for mobile air conditioning and off-cycle emissions, which might be incorporated into the Global Technical Regulation, or in a 1958 Agreement UN Regulation, or in an EU Regulation. Two subgroups of the WLTP informal group were set up to complete the work on Phase I of the Global Technical Regulation. The remainder of this section summarises their activities. Harmonised driving cycle The informal subgroup on the development of a harmonised driving cycle (WLTP-DHC) was asked to develop a cycle that represents typical driving conditions around the world. The group collected in-use data from the European Union, India, Korea, Japan and the United States and applied weighting factors to take account of differences in traffic volume. A first version of the driving cycle was completed in 20119. The cycle lasts 1,800 seconds and comprises four (speed) phases: low; middle; high; and extra high. Some general characteristics of the driving cycle are shown in the table below.

7 Working paper No. WLTP-03-03 (3rd WLTP meeting, 10 June 2009) 8 Informal document No. WP.29-148-22 (148th WP.29, 23-26 June 2009) 9 Working paper No. WLTP-DHC-09-02 (9th WLTP-DHC meeting, 6-7 July 2011)

Phase I (2009 - 2013)

Harmonised driving cycle (DHC)

Test procedure (DTP)

Off-cycle requirements (OCE)

Mobile air conditioning (MAC)

Phase II (2014 - 2018)

Low temperature high altitude

Durability

In-service conformity

On-board diagnostics (ODB)

Phase III (2019 - 2021)

Emission limit thresholds

Reference fuel properties

Correlation with existing regional

cycles

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Table 2.4: General characteristics of the WLTP-DHC driving cycle (Version 1)

Low Middle High Extra-

high

Unified

Cycle duration (s) 589 433 455 323 1800

Driving distance (km) 2.98 5.01 7.01 8.06 23.06

Average speed (km/h) 18.2 41.6 55.5 89.8 46.1

Maximum speed (km/h) 50.9 72.5 97.4 125.5 125.5

Maximum acceleration (km/h/s) 5.3 5.4 6.5 6.4 6.5

Maximum deceleration (km/h/s) -5.3 -7.4 -7.7 -4.1 -7.7

However, various concerns had been expressed regarding the extra-high speed phase of the driving cycle and alternative proposals were put forward. Slightly different variants of the sub cycles have now been derived for different vehicles, based on the power to weight ratios and to their maximum speeds. The vehicle classifications used in the WLTP and the driving cycles they are tested over are listed in the table below. Table 2.5 WLTP vehicle classes and their driving cycles. Subscripts refer to vehicle class

Class Power to weight ratio

(W/kg)

Maximum speed (km/h) Test cycle phase

(see Annex E)

1 ≤ 22 All Low1

Medium1

2 > 22 and ≤ 34 All

Low2

Medium2

High2

Extra-high2

3 > 34

< 120

Low3

Medium3-1

High3-1

Extra-high3

≥ 120

Low3

Medium3-2

High3-2

Extra-high3

The WLTC cycle refers to the complete set of phases listed above. In addition, the WLTC city cycle is the combination of the low and medium phases. Test procedure At the second meeting of the informal subgroup on the development of a test procedure (WLTP-DTP), it was agreed that several further subgroups (of WLTP-DTP) would be established to investigate and develop specific areas of the test procedure. These comprise: 1. Particulate mass and particulate number subgroup - Developing a measurement procedure and

specifications for particulate mass (PM) and particulate number (PN); 2. Additional pollutants subgroup – Developing test procedures for the measurement of ammonia,

nitrogen dioxide and nitrous oxide; 3. Lab process for internal combustion engine vehicles subgroup – Developing a test procedure

for the measurement of pollutants, carbon dioxide and fuel consumption for internal combustion engine vehicles;

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4. Lab process for electrified vehicles subgroup – Developing a test procedure for the measurement of pollutants, carbon dioxide, fuel/energy consumption and range for electric and hybrid electric vehicles;

5. Reference fuels subgroup – Defining validation fuels to support the development stages of the WLTP project and defining a framework for reference fuels to be used by contracting parties when applying the Global Technical Regulation.

The general approach adopted by these subgroups is to compare procedures in the contracting parties’ current legislation in order to derive content for the Global Technical Regulation. However, the subgroups will also specify a new procedure, where necessary; for instance, to achieve consensus on a particular issue or to take account of new research. Draft WLTP GTR Consolidated drafts of the WLTP GTR are available from the UN-ECE website. The following is related to the latest draft available at the time of writing: • WLTP-2013-023 Consolidated Draft GTR 30.06.2013 For vehicles with “complete or partial electric propulsion”, the following types are defined in the GTR: • “Pure electric vehicle (PEV)” means a vehicle with a powertrain where all energy converters are

electric machines and all storage systems are rechargeable electric energy storage systems (REESSs)

• “Hybrid electric vehicle (HEV)” means a hybrid vehicle (HV) with a powertrain containing at least one electric machine as energy converter.

The latter is subdivided into two sub-types: • "Not off-vehicle charging (NOVC)" means that the REESS cannot be charged externally, also

known as "not externally chargeable"; • "Off-vehicle charging (OVC)" means that the REESS can be charged externally, also known as

"externally chargeable"; Where: REESS (Rechargeable electric energy storage system) means a system storing electrical energy. The draft test procedure for internal combustion engine vehicles is currently very similar to that in UN Regulations 83 and 101. However, further work was specified by the subgroups to deal with a number of technical issues that remain open. The draft procedure for electric and hybrid vehicles is also very similar to the UN Regulations, but once again, the subgroups are working through a range of open issues. The current Road Map for the WLTP is shown in Figure 2.4. The aim is to submit a draft GTR as a formal document in August 2013 for approval at an ad-hoc GRPE session at the WP.29 meeting in November 2013.

32


Figure 2.4: WLTP Road Map

With regards to electric and hybrid electric vehicles (the focus for this study), the main performance tests and measurement parameters are unlikely to differ from those in the UN Regulations (and the EU type-approval Regulations). The WLTP group has no mandate to consider what new parameters may be needed to better inform consumers and legislators. The test procedure however has to be developed to improve the test of the vehicle and give more accurate data (see figure 2.5). Figure 2.5: WLTP E Lab sub group progress report, June 2012

Annex 8 of the draft GTR (dated 30.06.2013) is specifically aimed at vehicles with “complete or partial electric propulsion”. All these vehicles are classified as Class 3 vehicles and are tested over the full WLTC cycle and also over the WLTC City cycle. Hybrid vehicles with off-vehicle charging can be tested under either charge-depleting (CD) or charge-sustaining (CS) conditions, or in a combination of CD and CS conditions. The latter can be performed with either the charge depleting test first or with the charge sustaining test first.

2013 2014 2015 20163 4 5 6 7 8 9 10 11 12 1 4 7 10 1 4 7 10 1 4 7 10

WP.29 ☆ ☆ ☆ ☆ ☆ ☆ ☆ ☆ ☆ ☆GRPE ☆ ad-hoc ☆ ☆ ☆ ☆ ☆ ☆

draft meeting

Phase I gtr draft meeting 21 submit formal document formal document

Level 1(MUST items)

Level 2(can be postphoned to Phase II )

Phase II gtr Propose Phase II work schedule(ref.) work elements are listed on WP29-2009-131

Low temp. however, no specific time schedule is describedHigh alltitudeDurabilityCOPISCMACTPOff-Cycle

Dro

p-ou

tw

ork

elem

ents

Phase II gtr( it is one of possibilities to divide into 2 stages based on work elements)

solu

tion

resu

lt

33


As shown in table 2.5, it is currently proposed that Class 3 vehicles are tested over the low speed, medium speed, high speed and extra-high speed phases of the WLTP. The speed traces for these phases are contained in Annex E, and the maximum speeds are shown listed in the table below. Table 2.6. Maximum speed of the WLTP phases used for Class 3 vehicles

WLTC phase Max Speed (km/h)

Low3 56.5

Medium3-1 76.6

Medium3-2 76.6

High3-1 97.4

High3-2 97.4

Extra High3 131.3

To deal with vehicles that are unable to meet the maximum speed of the test cycles, the draft GTR has a down-scaling procedure. For Class 3 vehicles, this down-scaling only applies to the Extra High speed phase of the WLTC. For under powered vehicles, the highest speed section of the High Speed phase is reduced based on the “ratio between the maximum required power of the cycle phases where the downscaling has to be applied and the rated power of the vehicle”. A procedure is also provided to deal with vehicles which have sufficient power but with limited top speed (either through the vehicle’s gearing or due to the fitment of a speed limiter). And, if the vehicle is still unable to follow the speed trace, “it shall be driven with the accelerator control fully activated during these periods”. The draft GTR describes a number of different electric ranges which are determined during testing: • All-electric range

- in the case of OVC-HEV, means the total distance travelled from the beginning of the charge-depleting test over a number of complete WLTCs to the point in time during the test when the combustion engine starts to consume fuel.

- in the case of PEV, means the total distance travelled from the beginning of the charge-depleting test over a number of WLTCs until the break-off criteria is reached;

• Equivalent all-electric range (EAER) - means that portion of the total charge-depleting actual range (RCDA) attributable to the use of

electricity from the REESS over the charge-depleting range test • Charge depleting cycle range (Rcdc)

- means the distance from the beginning of the charge-depleting test to the end of the last cycle prior to the cycle or cycles satisfying the break-off criteria, including the transient cycle where the vehicle may have operated in both depleting and sustaining modes

• Charge-depleting actual range (Rcda) - means the distance travelled in a series of cycles in charge-depleting operation condition

until the REESS is depleted These are illustrated in Figure 2.6. A lot of discussion has gone into how to define the “break-off” criteria – this is the point that an OVC-HEV switches from a charge-depleting state into a charge-sustaining state (i.e. the power available from the traction batteries has run down to a stage that they start to require energy input from the engine). The current definition in the draft GTR is where the net energy change (NEC) is less than 4%, with NEC defined as:

Net energy change (per cent) = RCB ∗ nominal REESS voltage

cycle energy demand of the test vehicle × 100

34


Where RCB is the Charge Balance of the REESS measured in Ah. The cycle energy demand of the test vehicle will have to be calculated based on the mass of the vehicle being tested and its road load forces (used in the dynamometer setup). An initial draft procedure is provided, though it is not yet finalised.

35


Figure 2.6. Charge depleting test showing the various electric ranges

Fully Charged

Charge Depleting Cycle Range RCDC

Charge Depleting Range RCDA

CO2 emissions CD 12h charging

All Electric Range

Equivalent All Electric Range

First start of CE

Fully

Cha

rged

Precondi-tioning

Soak time +

Battery Charge

Test n-2 Test n-1 Test n (Transient cycle)

Test (First Sustaining

Test)

WLTC WLTC WLTC WLTC

10 ± 2 Minuten Soak

36


The methods and calculations to derive the energy consumption are also provided in the draft GTR. Other procedures in the draft include: REESS charge balance (RCB) compensation This method is for compensating for the change in the charge balance of the energy storage system, for both off-vehicle chargeable and not off-vehicle chargeable hybrids, when determining the fuel consumption and CO2 emissions. Fuel and CO2 correction factors are defined as:

𝐾𝑓𝑢𝑒𝑙 =𝑛 · 𝛴𝑄𝑖𝐹𝐶𝑖 – 𝛴𝑄𝑖 · 𝛴𝐹𝐶𝑖

𝑛 · 𝛴𝑄𝑖2 – (𝛴𝑄𝑖)2

And

𝐾𝐶𝑂2 =(𝑛 · 𝛴𝑄𝑖𝑀𝑖 – 𝛴𝑄𝑖 · 𝛴𝑀𝑖)

(𝑛 · 𝛴𝑄𝑖2 – (𝛴𝑄𝑖)2)

where: Kfuel is the fuel consumption correction coefficient, l/100 km/Ah FCi is the fuel consumption measured during ith manufacturer’s test, l/100 km KCO2 is the CO2 emissions correction coefficient, g/km/Ah; Mi is the CO2 emissions measured during ith manufacturer’s test, g/km; Qi is the electricity balance measured during ith manufacturer’s test, Ah n is number of data These “K” factors are then used to determine the fuel consumption and CO2 emissions at zero REESS energy balance:

𝐹𝐶0 = 𝐹𝐶 – 𝐾𝑓𝑢𝑒𝑙 · 𝑄

And 𝑀0 = 𝑀 – 𝐾𝐶𝑂2 · 𝑄

Electricity balance of the traction batteries in hybrid vehicles. The measurement of the electricity balance is necessary to determine when the minimum state of charge of the REESS has been reached during the test procedures; and to correct the measured fuel consumption and CO2 emissions for the change in REESS energy content occurring during the test. The method proposed requires a current transducer to be fitted to the REESS during testing and the output sampled at a minimum of 5 Hz (still to be confirmed) together with temperature at the location of the sensor. There is also a proposal that the manufacturer should “preferably integrate appropriate, safe and accessible connection points in the vehicle. If that is not feasible, the manufacturer is obliged to support the responsible authority by providing the means to connect a current transducer to the wires connected to the REESS.” Conditioning for PEV and OVC-HEV testing A procedure is proposed for preconditioning a PEV and OVC-HEV vehicles in preparation for electric range testing prior to testing. Typically the vehicle is driven over two consecutive WLTCs required for that class of vehicle. When conditioning for a charge-sustaining test, the charging balance of the REESS is recorded. If the charging balance is higher than specified, then additional cycles are performed. For a charge-depleting test, the REESS is charged during the soak period using the vehicle’s normal charge procedure.

37


Harmonised utility factors A method for determining harmonised utility factors for off-vehicle chargeable hybrid vehicles (to be used to weigh the CD and CS test results) has been proposed.

2.3 Electric Vehicles and the Environment Informal Working Group (EVE-IWG)

The EVE IWG was created under the UNECE 1998 Agreement, following the approval of a proposal by the European Union, Japan and the United States of America (document ECE-TRANS-WP29-AC.3-32e). The mandate of the EVE IWG is to last until November 2014. The group was set up as an open structure to enable the exchange of information and experience on relevant policies and regulations and to provide a forum for sharing information about developing techniques for important considerations such as measuring the energy efficiency of future electric vehicles, battery durability, cold start performance, and recharging performance. The application of fuel economy standards to electric vehicles and measurement of upstream emissions could be discussed as well. The main deliverable of the EVE IWG is the development of a Regulatory Reference Guide. The group is chaired by Michael Olechiw, United States with two co-chairs: Chen Chunmei, China and Kazuyuki Narusawa, Japan. The secretary is Stéphane Couroux, Canada. Progress on meeting the objectives of the group has been made, namely: • the Terms of Reference were adopted at EVE-02 (see EVE-02-23); and • at EVE-03, the EVE Leadership Team proposed a Regulatory Reference Guide approach and

outline. The EVE leadership team proposed to develop a questionnaire that would be sent to Contracting Parties and Informal Working Group members to fill-out. This general approach was accepted by the IWG.

There have already been 6 meetings of the EVE IWG – five face-to-face and one conference call. The dates and meeting summaries are listed in Table 2.7. Table 2.7 EVE-IWG previous meeting

Session number, location and

date(s)

Meeting summary

#1 – Geneva

8 June 2012

Discussion of drafted terms of reference

#2 – Baltimore

13-14 September 2012

Finalised TOR, initial discussions to develop an EV reference guide.

#3 – Conference Call

27 November 2012

Proposed a format for the reference guide and questionnaire.

#4 – Geneva

14 January 2013

Confirmed the format for the reference guide and questionnaire, initiated

information gathering.

Concurrence from GRPE on progress report and terms of reference

#5 – Tokyo

11-12 April 2013

Completed information gathering, discussion of completed questionnaires by

contracting parties and summary presentation.

#6 – Geneva

3 June 2013

Sought input from CPs (contracting parties) and other IWGs on list of priority

issues to inform reference guide recommendations and guide potential future

research/testing

All stakeholders invited to submit further literature/data.

38


The next steps for the group include: • Complete draft version of the Guide – Autumn 2013 • Present draft Guide to GRPE for comments and input - January 2014 • Present final guide to GRPE - June 2014 • Present guide to WP.29 – November 2014 (end of mandate) The upcoming meetings together with their provisional agenda items are listed in Table 2.8 . Table 2.8 Upcoming EVE-IWG meetings

Session number, location

and date(s)

Provisional agenda

#7 – Beijing, China

17-18 October 2013

Review first draft of reference guide and draft recommendation

#8 – Geneva

January 2014 GRPE

Submit second draft as an informal document to GRPE by Dec.1, 2013 to discuss

and receive comments during GRPE

#9 – To be decided

February 2014

Revise second draft based on GRPE comments

Discuss need for a new mandate for EVE

#10 – Geneva

June 2014 GRPE

Submit third draft as a formal document to GRPE by March 1, 2014

Seek final approval at Nov. 2014 WP.29 following GRPE concurrence

EVE-IWG prioritisation discussion points The following items have been raised as requiring priority during the forthcoming discussions within the group, summarised in Figure 2.7: 1) Vehicle Energy Efficiency/Range 1.a) Cabin Heating Background: EVE-04-05e submitted by Dr. Tober: The total add. energy req. for climate control

@ +10°C: 10 - 20 %, @ -10°C: 40 - 55%. Elements to form recommendation in EV Reference Guide: • Pre-conditioning prior to vehicle usage would decrease effect on range though not necessarily

total energy usage from the grid. • Heated seats & steering wheel. • Advanced technologies (Infra-red panels & heat pumps). • Accounting for these parameters in a test cycle to justify higher cost of advanced technologies. 1.b) A/C Background: EVE-04-05e submitted by Dr. Tober: The total add. energy req. for climate control

@ +10°C: 10 - 20 %, @ -10°C: 40 - 55%. Elements to form recommendation in EV Reference Guide: • Pre-conditioning prior to vehicle usage would decrease effect on range though not necessarily

total energy usage from the grid • Advanced technologies: such as heat pumps and electrified compressors • Zeolite 1.c) Potential battery temperature effect on capacity and efficiency Background: Meyer, N et al (2012) "The Impact of Driving Cycle and Climate on Electrical

Consumption and Range of Fully Electric Passenger Vehicles" reports a 15-20% loss of range for a variety of test cycles comparing 20 C and -20 C; and two tests

39


indicate a relatively small difference in efficiency but it is not clear whether these are within the variation of the testing procedure

Elements to form recommendation in EV Reference Guide: • End-of-range is believed to occur sooner in cold temperatures, but it is uncertain what portion of

the lost range is due to actual lost energy (i.e. reaching minimum SOC faster due to reduced discharge and regenerative efficiency) vs. depressed voltage triggering an end-of-range condition at a higher SOC while energy still resides in the battery. The first case means an increase in energy consumption while the second does not (the unused energy will become accessible as the battery rests/warms, or will reduce the energy needed to recharge).?

• Vehicle thermal management systems differ greatly 1.d) Potential battery state of charge effect on efficiency? Elements to form recommendation in EV Reference Guide: • Potential for energy loss with increased demand from the BMS (battery management system).

There may be increased cooling demands as well as cell balancing demands in the case of Li-ion batteries.

1.e) Road gradient Background: EVE-04-05e: A +2% Road Gradient results in 30%-50% higher energy

consumption. The energy saving at -2% is nearly as high as the higher energy demand at +2%".

Elements to form recommendation in EV Reference Guide: • Regenerative braking efficiency 1.f) Energy equivalency conversion methods? Elements to form recommendation in EV Reference Guide: • Comparison on an energy or an energy-fuel basis - Future need to regulate energy efficiency

(i.e. maximum kWh per km) 2) Battery performance/durability 2.a) Battery durability effect on range Background: Highly chemistry dependent, some research is available from Nissan10: Elements to form recommendation in EV Reference Guide: • Chemistry variations- Battery management system control of depth of charge and recharging

rates • Thermal management systems 2.b) Potential battery durability effect on kWh/km Elements to form recommendation in EV Reference Guide: • Chemistry specific effects • Surface-film 2.c) Battery performance effect on emissions Elements to form recommendation in EV Reference Guide: • Reduced all electric range for PHEVs resulting in ICE starting sooner & running longer 2.d) Battery management system performance Elements to form recommendation in EV Reference Guide:

10 http://www.mynissanleaf.com/assets/An%20open%20letter%20to%20Nissan%20LEAF%20owners%20from%20Carla%20Bailo_FINAL.pdf

40


• Cell-balancing • Thermal management draw • Other parasitic losses Information Sharing Items (Outside of WP.29) 3) Regulatory incentives Elements to form recommendation in EV Reference Guide: • HOV (High Occupancy Vehicle) lane use • Manufacturer credits 4) Regulatory Standards Incorporating EVs into fuel economy standards 5) EV charging Elements to form recommendation in EV Reference Guide: • Charge rate vs. charger efficiency • Level 2 home charging stations are not made by the same manufacturer of the vehicle and

efficiency could vary between manufacturers • Effects of various cell-balancing mechanisms

Figure 2.7 Illustration of the vehicle attributes for the EVE-IWG Reference Guide discussions

Vehicle:• Electrified Vehicle range• Energy consumption/efficiency• Vehicle driver-user information • Vehicle recycling and re-use• Vehicle labeling

Market Deployment Support:• Regulatory incentives

Infrastructure:• Wireless charging • On-board charging system• Off-board charging standard

related to the vehicle • Vehicle as electricity supply

Battery:• Battery performance• Battery durability • Battery recycling• Battery re-use (post-

mobility)

Within WP29 scopeNot sure if within WP29 scopeLikely not within WP29 scope

Illustration of Vehicle Attributes for EVE Reference Guide discussion

Annex:• Financial incentives• Consumer awareness • Government purchasing

41


2.4 Other international legislation

Most, if not all, countries or regions of the world apply legislation to control the emissions from light passenger and commercial vehicles. The approach to emissions measurement around the world is generally similar to the European legislation. The vehicle is subject to a temperature soak and preconditioning drives before the main emissions measurement is made over a pre-defined driving cycle. However, there are various differences in the technical details of the test procedures. An initial comparison of emissions and fuel consumption test procedures was made (by the expert from OICA) in preparation for the Global Technical Regulation on worldwide harmonised light-vehicle test procedures11. The European Union, Japan and the USA were the main focus of the comparison. The principal areas of difference were: • Drive cycles; • Inertia classes; • Determination of road load; • Off-cycle tests; • Ambient conditions; • Measured/regulated components; • Durability; • Soak time. The Indian experts made a similar analysis for a meeting of the Global Technical Regulation subgroup on test procedures12. This included Indian legislation (alongside European, Japanese and United States) and also highlighted the main differences such as the characteristics of the driving cycle. The Indian experts also made a more detailed comparison of the test procedure in the draft Global Technical Regulation against the European, Indian and Japanese legislative test procedures. This compared the main specifications in the draft Global Technical Regulation with corresponding specifications in the legislative tests. A further comparison of international test procedures was made by the participants of the subgroup on the lab process for electric vehicles13. This work focussed mainly on the range test procedure and compared the procedure in UN Regulation 101 with the corresponding procedures in a United States standard (SAE J1634) and a Japanese legislative test (TRIAS 5-10-2010). In general, the same basic procedures and measurement parameters are used for emissions and fuel/energy consumption legislation around the world. However, there are various differences in the way the tests are carried out and, as described in Section 2.2, there are global efforts to harmonise these differences through the development of a Global Technical Regulation.

2.5 Summary

This section reviewed the emissions and environmental utility legislation for light passenger and commercial vehicles including any specific provisions for hybrid and purely electric vehicles.

11 Working paper No. WLTP-02-09 (2nd WLTP meeting, 14 January 2009) 12 Working paper No. WLTP-DTP-01-08 (1st WLTP-DTP meeting, 13-15 April 2010) 13 Working papers WLTP-DTP-E-LabProc-006 to 009 (WLTP-DTP-E-LabProc meeting, 24-25 November 2010)

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Current legislation The European type-approval legislation was the main focus for the review and the main aim was to identify the measurement parameters that are currently specified to control air pollution and help consumers to make an informed choice when buying a new car. The table in Annex B summarises the type-approval legislation and sets out the type of tests that are required, their approach and the main measurement parameters. Table 9 sets out the parameters that are measured. Clearly, in the real-world, the performance of the vehicle will depend on a range of factors including driving style, driving conditions, ambient temperature and the use of ancillary devices such as heating or air conditioning. Such factors are currently not covered by existing European legislation or the draft GTR. Table 2.9 Overview of measured parameters in type-approval legislation

Parameter Units

Regulated pollutants (i.e. with limit values)

Emissions of carbon monoxide g/km

Emissions of total hydrocarbons (positive-ignition engines only) g/km

Emissions of non-methane hydrocarbons (positive-ignition engines only) g/km

Emissions of oxides of nitrogen g/km

Emissions of combined hydrocarbons and oxides of nitrogen (compression-ignition engines

only)

g/km

Emissions of particulate matter g/km

Number of particulates (compression-ignition engines only) number/km

Environmental utility parameters (i.e. no limit values)

Emissions of carbon dioxide g/km

Fuel consumption (urban) l/100 km

Fuel consumption (extra-urban) l/100 km

Fuel consumption (combined) l/100 km

Energy consumption (electric and hybrid vehicles only) Wh/km

Electric range (electric and hybrid vehicles only) km

Legislation under development An important issue is the introduction on the new WLTP (worldwide harmonised light-vehicle test procedures). A draft procedure is nearing completion within UNECE and it is hoped this will be adopted in 2014 and applied to vehicles from 2017. The main drive at the moment is to develop the procedures for the type 1 test – the main emissions test – together with fuel consumption and energy consumption measurements plus range for electric vehicles. An annex is already provided in the draft GTR dealing with electric and hybrid vehicles. Other aspects will then be considered at a later date, including off-cycle emissions, air conditioning, low temperature & high altitude effects and in-service conformity. Future legislation Follow-on stages of the WLTP work will include: • off-cycle emissions (OCE), • mobile air conditioning (MAC), • low temperature & high altitude effects • in-service conformity. Although these are mainly aimed at conventional vehicles, they will have implications for EVs and HEVs – especially air-conditioning and temperature effects.

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Limitations of the legislation Although the amount of energy needed to recharge the batteries is required as part of the fuel/energy consumption tests, there is currently no requirement to report the time needed to recharge the vehicle. The tests are also carried out with relatively new battery packs – there is no information available on the performance of these batteries as the vehicle ages. Also, the procedures for hybrids refer to vehicles with electrical energy storage systems. Although most of the procedures could quite easily be applied to other types of energy storage system (e.g. flywheel or hydraulic air) some are specific to electrical systems – for example, the method to derive a correction factor for the energy balance of a non-OVC hybrid is based on measuring the current flow.

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3 Two or three wheeled motor vehicles (L-category): Review of existing and legislation and regulations under development

This section reviews the legislation for mopeds, motorcycles, tricycles, and quadricycles. These are classified as Category L vehicles according to Directive 2002/24/EC (as amended) and UN R.E.3. Category L quadricycles (L6 and L7), to distinguish them from M1 and N1 vehicles, are defined as having an unladen mass not exceeding 400 kg for passenger vehicles or 550 kg for goods vehicles and a maximum continuous rated power of the propulsion system not exceeding 15kW. This study has reviewed the current European type-approval legislation for the environmental performance of vehicles and other aspects relevant to the performance of EVs and HEVs, as well as the proposed upcoming changes to the legislation. Subsection 3.1 provides an overview of the existing legislation, and describes the main performance tests. Subsections 3.2 and 3.3 discuss future legislation under development and a short summary is provided in Subsection 3.4. European Union (EU) type-approval of two- or three-wheeled vehicles and quadricycles with respect to their emissions is set out in Directive 97/24/EC and subsequent amendments (described hereafter as “current legislation” and discussed in more detail in section 3.1). In line with the recommendations of the CARS 21 report (EC, 2006), the current directives are in the process of being repealed and replaced with a regulatory package of delegated and implementing acts, within a framework provided by Regulation (EU) No. 168/201314 (known as the “Co-decision Act”, and discussed in section 3.2 as “legislation under development”). This is intended to aid competitiveness of the European automotive industry while tackling safety and environmental performance and at the same time simplifying type-approval legislation for L-category vehicles15. A second step in the process is harmonising the L-category legislation internationally through the United Nations European Commission for Europe (UNECE), referring as much as possible to international standards such as UN Regulations (R) and Global Technical Regulations (GTR). These regulations are part of a new regulatory approach that has been introduced into European Community vehicle legislation (sometimes called the “split level approach”). The overall package of co-decision, delegated and implementing acts is summarised below. Note that these acts will be Regulations rather than Directives; which enables them to automatically come into effect within all EU member states. Co-decision act: • Regulation (EU) No 168/2013 This entered into force on the 20th day following publication in the Official Journal of the European Union (March 2013), with the first parts of the legislation applying for new vehicle types from the 1st January 2016.

14 OJ L60 2.3.2013 p.52 15 The limits for L7 vehicles have changed slightly, to be “mass in running order” (defined by Article 5 as: the mass of the vehicle

including liquids, fuels and standard equipment, but excluding the mass of the driver, passenger, traction batteries, gaseous and compressed air fuel systems) not exceeding 450 kg (passenger vehicles) and 600 kg (goods). A 90 km/h maximum speed limit also applies, alongside the existing 15 kW power limit, depending on the sub-category.

45


Delegated acts: • REPPR – Regulation on environmental and propulsion performance requirements • RVCR - Regulation on vehicle construction and general requirements • RVFSR - Regulation on vehicle functional safety requirements

Implementing act: • RAR - Regulation on administrative provisions All of the delegated and implementing acts are in an advanced drafting stage, and are likely to be completed during 2013-14. 3.1 Current European type-approval legislation

The current Directive 97/24/EC as amended specifies a series of environmental tests, such as emission and sound level tests according to the vehicle classification, engine type and fuel. The application of the emission tests for type-approval and extensions is shown in Table 3.1 . Table 3.1 Application of tests in Directive 97/24/EC Vehicle category Vehicles with positive ignition

engines including hybrids

Vehicles with compression ignition

engines including hybrids

Mono fuel Mono fuel

Reference fuel Unleaded petrol Diesel fuel

Gaseous pollutants (Type 1 test) Yes Yes

Idle emissions (Type 2 test) Yes Yes

Smoke opacity - Yes

Regarding non-conventional propulsion types, there are specific requirements for testing hybrid motorcycles (see section Motorcycle, Hybrid electric: Type 1 test), including adaption of the type 1 and type 2 and an additional electric range test. There are not, however, any mentions of pure electric vehicles (EV) or fuel cells, nor test specifications for mopeds. Reference fuels Directive 70/220/EEC16 as amended (Annex IX, Section 1-2) specified the fuels to be used during emission tests for M1, N1 and L-category vehicles. This Directive however was repealed on the 1st January 2013 by Regulation (EC) No 715/200717 on the emissions of M1 and N1 category vehicles. When Regulation (EU) 168/2013 and the REPPR come into force for L-category vehicles the fuel requirements will be changed (see subsection 3.2). In the case of engines lubricated with a mixture of oil added to the reference fuel (i.e. 2 stroke PI engines), there is no “reference oil” as the specifications of the oil must match the requirements of that specific engine, instead it must comply as to type, quality and quantity with the manufacturer's recommendations. Tests Vehicles within Category L are divided into two main groups: low speed and light types; and high speed and heavy types.

16 Directive 70/220/EEC. URL http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31970L0220:EN:NOT 17 Regulation (EC) No 715/2007. URL http://eur-

lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:171:0001:0001:EN:PDF

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The low speed and light types include; two-wheeled mopeds, three-wheeled mopeds and light quadricycles, this grouping is collectively termed mopeds. All of the procedures and values mentioned assume that the vehicle is a moped, and only when there is a specific difference, in the limit values for instance, are three-wheeled mopeds and/or light quadricycles mentioned. The high speed and heavy types of L-category vehicles include; motorcycles, motor-tricycles and heavy quadricycles. This group can therefore be further expanded to include; motorcycles with sidecars, quadri-mobiles (mini-cars) and quadricycles like all-terrain vehicles and on-road quads. This grouping is collectively termed motorcycles, tricycles and quadricycles. For each vehicle group there are two main tests in Directive 97/24/EC: • Type 1 test: Verifying the average exhaust emissions at ambient conditions; • Type 2 test: Measuring carbon monoxide at idling speeds; In addition to testing conventional PI engines, there are alternative methods for performing these tests on hybrid and compression-ignition engine based motorcycles; and a procedure for measuring the electric range of hybrid vehicles. Although there is no requirement for pure electric or hybrid human electric vehicles, this could be related to there not being a requirement to publish performance data such as fuel/energy consumption or range for L-category vehicles. For the two Category L groups there are different test requirements (see the table below). In addition, an amendment to Directive 97/24/EC by Directive 2006/27/EC made it permissible for manufacturers of the higher speed two-wheeled Category L vehicles (i.e. motorcycles), to opt for an alternative test. The World-harmonised Motorcycle Test Cycle (WMTC), detailed in UN Global Technical Regulation No 218 (see section Motorcycles, motor tricycles and heavy quadricycles). Table 3.2: L-category vehicle test type 1 cycles, Directive 97/24/EC Cycle Moped Motorcycle

2, 3, 4 wheeler 2 wheeler 3, 4 wheeler

R47 X

R40 X X

WMTC (stage 1) X

In the following sections the particular tests will be explained for each vehicle group. Moped, Type 1 test: Verifying average exhaust emissions of gaseous pollutants in a congested urban area The Type 1 test evaluates a vehicle’s running emissions after a warm start. It is performed under laboratory conditions with a chassis dynamometer that is adjusted to simulate the road load force that would act on the vehicle on the road. The main technical requirements for the test are set out in Annex I of Directive 97/24/EC, which in turn refers to Annex 4 of UN Regulation 47, the UN Regulation is not however acceded to by the EU and cannot be used as an alternative; although the cycle is the same, the sampling regime differs. For mopeds the vehicle under test must be run-in and driven at least 250 km before performing the type 1 test.

18ECE/TRANS/180/Add2. http://live.unece.org/trans/main/wp29/wp29wgs/wp29gen/wp29registry/gtr02.html

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http://live.unece.org/trans/main/wp29/wp29wgs/wp29gen/wp29registry/gtr02.html

The test cycle is made up of four urban cycles, each comprising of 6 phases (idling, acceleration from 0 – 45 km/h, steady speed of 45 km/h (or the vehicle’s maximum design speed), deceleration from 45 – 20 km/h, steady speed of 20 km/h and deceleration 20 km/h – 0). This is shown in the figure below. The vehicle proceeds through a pre-defined driving cycle; the first four cycles are only used to warm the vehicle, there is no emission sampling, which means that cold emissions are not used in the final test result. The cycles are then repeated a further 4 times and it is the exhaust gases from these cycles that are diluted, sampled and analysed. Due to regional variations in the classification of mopeds, there are two maximum vehicle speeds which the majority of the vehicles are classified into, 45 km/h and 25 km/h, these are shown in the plot of the cycle as the red and blue traces. Figure 3.1: Graphical plot of UN R47 driving cycle

For this test, the time is fixed, however the distance travelled and average speed is dependent on the capabilities of the vehicles. Unlike some test cycles, there are parts where deviation from the line is permitted, specifically the first acceleration which is simply performed at maximum throttle, similarly for the high speed cruise the actual speed depends on the capabilities of the vehicle. It is therefore important that the distance travelled is recorded, as the emissions produced are divided by the distance travelled. The following table details the general characteristics of the driving cycle for both a high and low speed moped.

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Table 3.3: General characteristics of the UN R47 driving cycle

Example Low speed moped (≤ 25

km/h)

Example High speed moped

(≤ 45 km/h)

Average speed during test est. 18 km/h est. 24 km/h

Effective running time 112 s per part

(448 s for 4 measured parts, 896 s total driving time)

Theoretical distance covered per

cycle

est. 0.57 km

(4.54 km for the eight cycles)

est. 0.75 km

(5.97 km for the eight cycles)

Maximum speed

(±5 km/h or 10%)

25 km/h 45 km/h

Maximum acceleration Unknown, example based on 0.56 m/s2

Maximum deceleration -0.93 m/s2

The time when the first deceleration starts is not defined, instead it changes depending on the maximum vehicle speed and acceleration rate of the vehicle and therefore preliminary tests. Preliminary tests are used to enable the test driver to get used to the vehicle, determine how best to actuate the controls, when to change gear, etc. The main emission limits, as laid down in Directive 97/24/EC chapter 5 Annex I, are applied to the mass of carbon monoxide and the combined hydrocarbons and oxides of nitrogen (HC + NOx). Three-wheeled mopeds & light quadricycles are allowed 3.5 times higher emissions of CO than two-wheel mopeds. The limits of HC + NOx are the same for both groups. It should be noted that no distinction is made between different hydrocarbon types, therefore this is taken to mean total hydrocarbons. Moped, Type 2 test: Measuring carbon monoxide emission and unburnt hydrocarbons emissions at idling speeds Immediately following the type 1 test; while the vehicle is still warm, the type 2 test is performed to measure the idling emissions. The neutral gear is selected in whichever way is appropriate for the type of gearbox fitted. The engine is then started and a maximum of 1 minute is given to let the vehicle reach equilibrium, after which the carbon monoxide and hydrocarbon content of the exhaust gases is measured for exactly 1 minute. The results are recorded as a percentage of the emissions. There are no limits for Test 2, the values are just recorded for information. In addition however, this test may be used by a manufacturer for internal quality of production; to benchmark other vehicles coming off the production line, as is required for M1 and N1 category vehicles19. Particulate matter is measured by way of an opacity test with compression ignition engines only in test type II to accommodate road worthiness testing. Motorcycles, motor tricycles and heavy quadricycles The tests which these vehicles must perform, as well as the emission limits for these tests, varies by sub-type, engine type, vehicle power and maximum speed. The tests include an emissions test while performing a driving cycle on a dynamometer, an idling test performed after the driving cycle for positive injection engines, an opacity test of the exhaust gases for compression ignition engines, and an electric range test for hybrid vehicles.

19 Directive 2007/46/EC as amended. URL http://eur-ex.europa.eu/LexUriServ/ LexUriServ.do? uri=CONSLEG:2007 L0046:20130110:EN:PDF

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http://eur-ex.europa.eu/LexUriServ/

Motorcycle, Type 1 tests: Verifying average exhaust emissions at ambient conditions The Type 1 test evaluates a vehicle’s running tailpipe emissions. Motorcycles must perform the test after a cold start, while motor tricycles and quadricycles perform a warm start, i.e. the emissions are recorded only after a portion of the cycle has been driven to warm the engine. It is performed under laboratory conditions with a chassis dynamometer that is adjusted to simulate the road load force that would act on the vehicle on the road. The vehicle proceeds through a pre-defined driving cycle and the exhaust gases are diluted, sampled and analysed. The main technical requirements for the test are set out in Chapter 5 of Directive 97/24/EC, which in turn refers to UN Regulation 40 where the driving cycle is defined, and alternatively to UN GTR No. 2, where the World-harmonised Motorcycle Test Cycle (WMTC) driving cycle is defined. However it should be noted that the EU has not acceded to UN Regulations 40 and 47, which means that a manufacturer can only type-approve the environmental performance of an L-category vehicle according to EU legislation. Before all of the main emissions tests, the vehicle must ‘soak’ for at least six hours at a temperature of 293-303 K (20°C-30°C), and until the engine oil temperature and coolant (if any) are within ±2 K of the room temperature. For motorcycles the vehicle must be run-in by driving at least 1,000 km20. Motorcycle, Type 1 test: WMTC Driving cycle In the current Regulation, only two-wheeled motorcycles are permitted to perform the WMTC driving cycle, the manufacturer has the option to perform it as an alternative to the R40 driving cycle. Within the WMTC shown in Figure 3.2 there are 3 parts, relating to slow, medium and fast vehicle speeds driven within a fixed timeframe. This should be considered as independent parts, as they are not necessarily performed in the order commonly represented. • Part 1 is made up of a slow speed urban driving cycle comprising a complex range of phases

(idling, acceleration, steady speed, deceleration, etc.) including 8 stops, representative of driving around a congested city.

• Part 2 is made up of a medium speed urban driving cycle including only one stop but rather a sequence of accelerations and decelerations, representative of driving around non-congested city consisting of higher speed roads.

• Part 3 is a high-speed extra-urban driving cycle, comprising of smaller speed changes, representative of driving on a motorway.

Depending on the vehicle’s propulsive performance or engine capacity, the vehicle’s class and sub class is ascertained. UN GTR No 2 states three classes of vehicle, with five sub classes. However the EU directive uses only two classes with no sub classes. These are; vehicle capable of < 130 km/h perform parts 1 and 2 consecutively, and vehicle capable of ≥ 130 km/h perform parts 1, 2 and 3 consecutively (see Figure 3.2, and the line; Normal Speed Stage 1). In addition the EU uses the stage 1 trace and doesn’t use the reduced speed sections. A motorcycle is placed on a chassis dynamometer, the appropriate cycle trace is presented to the test rider using a driver’s aid, and the vehicle is subjected to the test. The required parts are

20 Directive 97/24/EC, Chapter 5, Annex II, Appendix I, Section 3.1.1.

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completed with no interruption. This test is performed in a cold condition and the emissions from all parts ridden are used in the final result.

Figure 3.2: Graphical plot of WMTC driving cycle

Taking the two possible configurations used in Directive 97/24/EC the cycle has the following characteristics: Table 3.4: General characteristics of the UN GTR No 2 (WMTC) driving cycle

Part 1 and 2 Part 1, 2 and 3

Average speed during test 39.5 km/h 58 km/h

Effective running time (±0.5 s) 1,200 s (20 min) 1,800 s (30 min)

Distance covered (±2 %) 13.18 km 28.9 km

Maximum speed

(±1 km/h)

94.9 km/h 125.3 km/h

Maximum acceleration 9.7 ms-2 9.7 ms-2

Maximum deceleration -7.2 ms-2 -7.2 ms-2

Motorcycle, Type 1 test: UN Regulation 40 Driving cycle With the UN Regulation 40 driving cycle shown in Figure 3.3 there are two parts; the Elementary Urban Cycle (EUC) and Extra-Urban Driving cycle (EUD). These equate to the terms Urban Driving Cycle (UDC) and Extra-Urban Driving Cycle (EUDC) respectively, used for Category M1 and Category N1 vehicles in the New European Driving Cycle (NEDC), set out in Annex 4 of UN Regulation 83 (see figure below). The NEDC and R40 cycles are essentially the same, except L-category vehicles perform an additional two super cycles at the start for pre-conditioning, i.e. to warm the vehicle with the emissions not measured. This is only the case for motor-tricycles and quadricycles, whereas for motorcycles, a cold start is used, with the emissions measured for the whole driving cycle, including the additional 2 super cycles.

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Figure 3.3: Graphical plot of UN Regulation 40 driving cycle

Motor tricycles and quadricycles perform the UDC part only, whereas for motorcycles, the EUDC part is also performed. The parts of the driving cycle which the vehicle performs depend on which of the three classes the vehicle falls into: • If the vehicle’s engine capacity is < 150 cm3 it performs the UDC part only, • For vehicles with a capacity of ≥ 150 cm3 & maximum speed < 110 km/h they perform the UDC

and a modified EUDC with a maximum speed of 90 km/h • And for vehicles with a capacity of ≥ 150 cm3 and a maximum speed of ≥ 110 km/h they perform

the UDC and EUDC with a maximum speed as stated in the test specification. The UDC is made up of 6 super cycles, each comprising of 14 phases (idling, acceleration, steady speed, deceleration). These can be grouped into three elementary cycles: The first is from idle to 15 km/h (idle, acceleration, steady state, deceleration), the second is the same as the first but takes the vehicle from idle up to 32 km/h and the third consists of 5 stages (idle, acceleration, steady state, deceleration, steady state, deceleration) up to 50 km/h and then progressively down to 35 km/h. The acceleration and deceleration rates are given, as well as exact times and speeds when to apply the clutch and change into neutral. The vehicle must stay within ± 1 second of the timings and ± 1 km/h of the speeds defined. For two-wheeled motorcycles, they are also required to perform the EUDC part. The EUDC is made up of only one extra urban cycle comprising of 13 phases; the cycle does not have idle periods except for the start and end and reaches a peak speed of 120 km/h. The top speed can be capped at 90 km/h for vehicle not capable of over 110 km/h in which case there are 11 phases. If applicable, the first and second parts are completed consecutively with no interruption.

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Table 3.5 General characteristics of the UN Regulation 40 driving cycle

EUC EUC + EUD

EUC + EUD reduced

speed

Average speed during test 13.9 km/h 19.7 km/h 19.1 km/h

Effective running time (±0.5 s) 1,170 s (19.5 min) 1,570 s (26.2 min) 1,570 s (26.2 min)

Distance covered (±2 %) 21,573 m 46,610.5 m 45,195.5 m

Maximum speed

(±1 km/h) 50 km/h 120 km/h 90 km/h

Maximum acceleration 1.04 ms-2 1.04 ms-2 1.04 ms-2

Maximum deceleration -0.92 ms-2 -1.39 ms-2 -1.39 ms-2

Type 2 test: Measuring carbon monoxide emission at idling speeds This test is performed on positive ignition vehicles only. This test must be performed immediately following the appropriate type 1 test. The vehicle is placed in neutral and the clutch engaged in whichever way is appropriate for the gearbox fitted. The vehicle may idle at Normal and High (> 2,000 min-1) idle. In either case the carbon monoxide content of the exhaust gases is measured as well as the engine speed. As with the Mopeds, this test is recorded for information only. The vehicle does not have to pass any limits and the value is not currently used at a later stage for any legislative reasons. Motorcycle, Hybrid electric: Type 1 test Hybrid electric vehicles must comply with the same emission limits as conventional vehicles; however, there are some differences in the way the test is carried out, and particularly in the preparation and conditioning of the vehicle. The Directive defines four categories of hybrid electric vehicles, as shown in the table below, which determine how the test is carried out. Table 3.6: Categories of hybrid electric vehicles in Directive 97/24/EC

Vehicle charging Off-vehicle charging Not off-vehicle charging

Operating mode switch Without With Without With

Hybrid vehicles featuring off-vehicle charging (also known as “externally chargeable” or “plug-in hybrid”) are tested under two conditions (regardless of the presence of an operating mode switch): • Condition A: Fully charged electrical energy/power storage device; • Condition B: Electrical energy/power storage device in minimum state of charge (maximum

discharge capacity). These hybrids are generally conditioned in the same way as conventional vehicles. For example, the same preconditioning cycles are performed according to the engine type and the vehicles are left to soak in the same temperature and for the same period. There are, however, additional procedures for hybrids for discharging the energy storage device, which vary depending on the presence of an operating mode switch and whether testing under Condition A or B. There are also specifications for charging the vehicles (when testing under Condition A). Hybrid vehicles which are not externally chargeable perform the test as a conventional vehicle would. And those with an operating mode switch must meet the limits in all hybrid modes. This does not necessarily mean a test for each mode, but is assessed based on information provided by the manufacturer.

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Motorcycle, Hybrid electric: Type 2 test If the vehicle is a hybrid then the test must be performed in the two conditions (A minimum and B maximum charge) as used for the type 1 test (see above). No additional clause is given for if the hybrid deactivates the engine during the test. However, for condition B where the battery is at minimum charge, the engine should be running. Furthermore, as the engine speed has to be recorded alongside the emission measurement it may be assumed that the engine may be forced to run in some manner in order to obtain a measurement. Motorcycle, Hybrid electric: Type 7 test (Electric range) Hybrid electric vehicles must also perform an electric range test. In this test the same cycle is used as for the type 1 test, and the vehicle must perform the driving cycle as applicable to that vehicle as many times as necessary to drain the battery. The vehicle must be run-in by travelling at least 300 km within the past week before performing the test. Considering that the type 1 test requires a minimum of 1,000 km; if the same vehicle is used, the manufacturer may choose to perform this test before the type 1. The test can be performed either in or outdoors, if indoors the test must be performed between 20 °C and 30 °C, for outdoors a temperature range of 5 °C to 32 °C is permitted. The battery must be fully charged in the correct method for that vehicle, which entails first fully discharging and then recharging the energy storage system overnight. Afterwards the test cycle is performed continuously until the energy storage has dropped below a certain level of performance. Although continuous, 15 minutes rest stops for the test driver are permitted between each iteration. Motorcycle, Additional tests: Measuring visible air pollution - Diesel This test is combined within the type 2 test in the L-category legislation under development. It is performed on compression ignition vehicles only. There are two tests to measure the visible air pollution, in both the vehicle’s exhaust emissions are fed through an opacimeter to measure their light absorption. In each of the tests the vehicle is run in multiple states were the intention is to find the worst case value to compare to the limits, which are measured as its absorption coefficient in m-

1. For these tests they may be performed on the vehicle on a chassis dynamometer or with the engine on an engine dynamometer. The first test is “steady-state operation test over the full load curve”. The vehicle performs the test used to find Net engine power from Directive 95/1/EC, and is performed on a brake dynamometer. The engine is run at 6 different speeds; minimum rated speed, maximum rated speed, the speed at which the engine developed the maximum power, the speed at which the engine developed the maximum torque, and two other speeds. The second test is “Free-acceleration test”. This test must either be performed immediately following the first test, or warmed up prior to running temperature as was measured at the end of the first test. From an initial state of idling, with clutch engaged and gearbox in neutral, the accelerator is applied to obtain maximum flow from the injector pump, until maximum engine speed has been achieved. If the engine has a turbocharger which can be disengage, the test must be run in both states. The overall limit is based on a combination of the two tests. Emission limits All of the measurements for test 1 are measured in g/km, test 2 has no limits, and the visible air pollution test for Diesel engines is measured as a coefficient of light absorption. The emission limits for test 1, shown in Figure 3.4, differ for each of the vehicle types and driving cycle performed.

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Motorcycles must perform to Euro 3 limits, while motor tricycles and quadricycles must reach the Euro 2 limits. Figure 3.4: Emission limits for L-category vehicle in mg/km. All are Euro 2 emission levels except for Motorcycles which are Euro 3

For 2 wheeled motorcycles, the Euro 3 emission limits are different depending on which test cycle is used. The limits for the WMTC cycle were determined using experimental data of vehicles performing both the WMTC and R40 cycles; to set limits which are comparable.

3.2 Legislation under development

The EU legislation related to type-approval of Category L vehicles is currently under review by the European Council and Parliament. Over the last decade the concentrated efforts into reduction of emissions in category M1 and N1 vehicles have meant that, although they have a smaller market share, Category L vehicles now contribute a significant proportion of the road emissions as indicated by the impact assessment produced by the European Commission21 in 2010. To rectify this, various initiatives and projects are currently underway to develop appropriate environmental measures for Category L vehicles. These will all feed into a small number of new

21 SEC(2010) 1151. Accompanying document to the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the approval and market surveillance of two- or three-wheel vehicles and quadricycles. Figure 1 and 2; For L-category vehicles, trend over time in absolute and relative shares of hydrocarbon/carbon monoxide emissions, assuming no change in policy. European Commission. 2010. Brussels. URL: http://ec.europa.eu/governance/impact/ia_carried_out/docs/ia_2010/sec_2010_1151_en.pdf

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http://ec.europa.eu/governance/impact/ia_carried_out/docs/ia_2010/sec_2010_1151_en.pdf

delegated acts under Regulation (EU) 168/201322. This entered into force on the 20th day following publication in the Official Journal of the European Union (March 2013). However, the actual testing methodologies are still under discussion and subject to change, so the following sections are based on the draft REPPR, as published in April 201323. One important change is the vehicle categories. This has been updated to clearly define the various vehicle types considered to be within the L-category; to allow all of them to be included within the scope, and to differentiate between each category and apply appropriate testing. The next improvement is the many proposed changes directly related to emissions. Below is an overview of the emission tests to be applied to the category (and of relevance to this study): • Type 1 test: Verifying the average exhaust emissions at ambient conditions; • Type 2 test: Measuring carbon monoxide at idling speeds and smoke opacity test (applicable to

CI vehicles only); • Type 3 test: Verifying emissions of crankcase gases; • Type 4 test: Determination of evaporative emissions; • Type 5 test: Verifying the durability of pollution control devices; • Type 7 test: Measurement of carbon dioxide emissions and fuel/energy consumption and a test

for electric range; • Type 8 test: On-board diagnostic tests.

Note, the type 6 test “Verifying the average emissions at low average temperatures” entails performing the type 1 test at -7°C. This is not performed on L-category vehicles due to their reduced use during cold weather conditions. Finally, the proposed scope has been expanded in comparison to the current legislation to encompass a wide range of emerging technologies. This includes requirements for many fuel types, fuel combinations and propulsion systems: • Propulsion types:

- PI, positive ignition (i.e. spark ignition), - CI, compression ignition, - EV, including Fuel cells and human / electric hybrid cycles - HEV

• Fuels: - E5 petrol - E85 ethanol - LPG - NG - Biomethane - H2 and NG mixture - B5 diesel - Biodiesel - Compressed Air

• Fuelling:

22 Developed in Regulation COM(2010) 542 final. European Commission (2010a). Proposed Regulation of the European Parliament and of the Council on approval and market surveillance of two- or three-wheel vehicles and quadricycles. European Commission, Brussels.

23 Draft Regulation on the environmental and propulsion performance requirements of two- or three-wheel vehicles and quadricycles (REPPR), revision 4. URL https://circabc.europa.eu/d/a/workspace/SpacesStore/a2b2889f-bf89-4f3d-ac16-04d16b430d18/5d1_REPPR_MCWG_2013_04_19_r4.pdf. European Commission, 19/04/2013. Brussels

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https://circabc.europa.eu/d/a/workspace/SpacesStore/a2b2889f-bf89-4f3d-ac16-04d16b430d18/5d1_REPPR_MCWG_2013_04_19_r4.pdf

https://circabc.europa.eu/d/a/workspace/SpacesStore/a2b2889f-bf89-4f3d-ac16-04d16b430d18/5d1_REPPR_MCWG_2013_04_19_r4.pdf

- Mono-fuel - Bi-fuel - Multi-fuel

Due to the similar behavioural characteristic of the propulsion types, many have been grouped together with the electric vehicles (EV). These include: • Pure Electric, usually when powered by a conventional battery; • Human / Electric hybrid, i.e. Pedelec (pedal electric cycle); • Fuel cell. Fuel cells are essentially batteries where the electrolyte is constantly replaced from a

tank, these generate electricity for an electric motor; • Compressed air. Almost all of these vehicles grouped as EV require no emission testing24, with the exception of compressed air, where particulates are measured. They all however must perform the fuel/energy consumption and range tests (Type 7), which is done to provide information to the consumer. It is clear that some of the tests are also not required for internal combustion engined vehicles. For instance, diesel has low volatility and therefore evaporative emissions are not measured. Similarly, if a vehicle has duel or multi fuel capability, only some of the fuels used produce the emissions being measured; for instance hydrogen (H2), though flammable is not a toxic gas. Annex C lists all the tests proposed for L-category vehicles depending on the fuel and engine type. The following sections summarise the specific tests, as proposed in Regulation (EU) 168/2013 and the draft REPPR, as published in April 2013. Euro limits The emission limits, tests and other test criteria are aligned with the Euro numbers. L-category vehicles are currently at Euro 2 (mopeds) and 3 (motorcycles). A road map has been developed to move, step by step, to full Euro 5 compliance for all L-category vehicles by 2020 (for new types) and 2021 (for existing types). The first step is being developed in a separate Euro 3 proposal for mopeds. For the type 1 test, it expands on the testing requirements for the R47 test cycle to also include the measurement of NOx, HC, CO2 and fuel consumption, but without changing the limit values themselves from those of Euro 2. In addition, all super cycles will be included in the emission measurement, i.e. the test will be changed from a warm start to a cold start, requiring the vehicle to be cooled before the test as is done for motorcycles. The previously unmeasured emissions will be weighted, providing 30% of the final result, the remaining four super cycles providing 70%. The emissions results from each part will be stored in separate bags, so that the emissions are not diluted between each part of the test.

24 Annex V(B) of Regulation 168/2013 sets out the precise requirements for all vehicle types. For hybrid vehicles, the fuel-type of the combustion engine determines which tests must be performed.

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Figure 3.5 Pollutant emission sampling Euro 3 compared to Euro 2 for an L1e, L2e or L6e category vehicle.25

The second step, starting in 2016 for new types, is to bring motorcycles, tricycles and heavy quadricycles to the Euro 4 level. For motorcycles the WMTC test will be changed to stage 2 and using the UN GTR’s class selection system. Thirdly, mopeds will be aligned with Euro 4 (for new types from 2017), with individual limits for all the emissions. Finally the Euro 5 step aligns all vehicle types with a single Revised WMTC test cycle in 2020. This revision of the WMTC opens its scope to allow vehicles with a swept capacity <50 cm3 and vehicles with more than two wheels to use the test cycle. In 2015 an environmental effect study will be performed by the EC in order for them to decide on any additional future steps, including limits and tests. Type 1 test: World-harmonised Motorcycle Test cycle (WMTC) In the current legislation26 the un-amended WMTC27 test, published in August 2005, is referenced for use in the type 1 emission testing. This version of the test cycle has been retrospectively named 'WMTC Stage 1'. In the legislation under development later UN and EC revisions of the test are proposed to be used. The following diagram and table show the full list of configurations from UN GTR No. 2, Stage 1 from 30th August 2005.

25 DISCUSSION PAPER Mopeds Euro 3 & AHO all rev.2. Motor cycle working group, Meeting on 19 April 2013. https://circabc.europa.eu/w/browse/528fde84-43f7-4345-b64a-fc3c778aa53e

26 Directive 97/24/EC as amended by Directive 2006/72/EC 27 WMTC is also known as the GTR 2 test in reference to the UN GTR where it was first defined

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Figure 3.6 Class identification from UN GTR No 2 (WMTC) driving cycle (stage 1)

Table 3.7 Part selection from UN GTR No 2 (WMTC) driving cycle (stage 1) Class Parts

Class 1:

Subclasses 1-1 and 1-2: part 1, reduced speed in cold condition, followed by part 1 reduced

speed in hot condition.

Subclass 1-3: part 1 in cold condition, followed by part 1 in hot condition.

Class 2:

Subclass 2-1: part 1 in cold condition, followed by part 2 reduced speed in hot

condition.

Subclass 2-2: part 1 in cold condition, followed by part 2 in hot condition.

Class 3:

Subclass 3-1: part 1 in cold condition, followed by part 2 in hot condition, followed by

part 3 reduced speed in hot condition.

Subclass 3-2: part 1 in cold condition, followed by part 2 in hot condition, followed by

part 3 in hot condition.

UN GTR No 2 was later amended, to include a more appropriate gear-shifting pattern and some other minor modifications which were considered to be neutral on the emission test results while better reflecting real-world driving. This is referred to as 'WMTC Stage 2', and was published in January 2008.The vehicle classifications were also modified which changed the overall cycle that some vehicles were required to perform. However, certain opportunities for improvement were identified following running the test on some vehicles common in India. This brought about further improvements to the gear changing procedures and adjusted cycles to match the slightly different acceleration rates. This completed 'WMTC Stage 2' and was published in September 2009. As stated before, at the second step to Euro 4 some vehicles are proposed to be moved to the WMTC stage 2 emission driving cycle. At the fourth step to Euro 5 all vehicles are proposed to be

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move to the Revised WMTC cycle, such that all L-category vehicles will be subject to emission testing with the WMTC in the type-approval process. The “revised WMTC” or “WMTC stage 3” features additional traces for low speed vehicles, currently grouped as mopeds. The trace will be capped at 45 km/h, and they will be permitted to perform the cycle at WoT (wide open throttle, i.e. full throttle) if the vehicle is unable to meet the required cruising speed, in addition to the current article for not meeting the required acceleration rates. Type 2 test: Idling emissions and free acceleration test The type 2 test is used to measure the emissions of a vehicle while not under load. The draft REPPR28 defines a change to the methods described previously in sections 3.2 and also changes the scope of the test’s use. The REPPR states that the proposed test is intended to meet the requirements of Directive 2009/40/EC amended by Directive 2010/48/EC, on roadworthiness of motor vehicles and their trailers, whereby directly linking the test to PTI in the same manner as is done for M and N category vehicles. Under the proposed legislation PI and CI engined vehicles perform different tests: • PI vehicles perform an idling test at two engine speeds • CI vehicles perform a free acceleration test, defined in Directive 2009/40/EC as amended PI vehicles The Idling test for PI engines is performed on the vehicle directly following the type 1 test so that the engine and emission abatement parts are warm. It is separated into two stages; idling, where the vehicle has no controls actuated apart from ensuring that the engine is running, by deactivating systems such as start-stop; and high-idle where the throttle is actuated to a manufacturer defined engine speed above 2,000 revs min-1. During the tests the following parameters are measured: • CO • CO2 • HC • O2 • Engine speed • Oil temperature, or water temperature if oil not available For each of these cases, the vehicle is adjusted to gain a range of results for different settings that could be obtained using standard adjustment tools. The emissions are taken first with the vehicle configured as fixed by the manufacturer, and then a variety of adjustments are made. The limits are given by Directive 2009/40/EC as amended, Annex II paragraph 8.2.1.2.. These limits which must not be exceeded both; with the vehicle at the manufacturers fixed settings, and when “… continuously varying each of the adjustment components in turn while all other components are kept stable…”. The limit values are presented below. • CO

- Either, gaseous emissions exceed the specific levels given by the manufacturer; - Or, if this information is not available, the CO emissions exceed

• for vehicles not controlled by an advanced emission control system, - 4.5 %, or 3.5 %

• for vehicles controlled by an advanced emission control system,

28 REPPR r4 April 2013, Annex II, page 203

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- at engine idle: 0.5 % or 0.3 % - at high idle: 0.3 % or 0.2 %

• Lambda - outside the range 1 ± 0.03 or not in accordance with the manufacturer’s specification

• OBD - readout indicating significant malfunction

The choice of value depends if the vehicle was registered after 1st July 2008. This date seems to refer to light duty vehicles, and it is not yet defined in the draft REPPR which of the two values to use. CI vehicles For CI engine vehicles the type 2 test measures opacity of the exhaust gases and not their gas content. The test and limits are entirely defined within Directive 2009/40/EC as amended, Annex II, 8.2.2.229. The vehicles must be warm, (i.e. following the type 1 test) and with the vehicle’s transmission not engaged the throttle is depressed to bring it up to its maximum engine speed. The vehicle limits are: • Opacity

- Either, gaseous emissions exceed the specific levels given by the manufacturer; - Or, Where this information is not available or requirements do not allow the use of reference

values: • for naturally aspirated engines: 2.5 m-1 • for turbo-charged engines: 3.0 m-1

Or • 1.5 m-1

As stated above, it is not yet defined in the draft REPPR which of the two values should be used. Hybrids, bi- and multi-fuel vehicles REPPR, Annex II, Appendix 11, contains specific requirements for adjustments to the tests regarding hybrid vehicles. Currently only the specifications for the type 1 test are given. Paragraph 4, as referred to from the type 2 test, has not been published. As shown in appendix D, the type 2 test will be performed on all fuel types, however where there is a bi-fuel or flexi fuel vehicle the alternative is not always tested. The test is not performed on pure EV, compressed air or fuel cell vehicles. Type 3 test: Crankcase emissions The crankcase is the area below the pistons in an internal combustion engine, it contains the crank which converts the linear motion of the pistons into rotational motion, then transfers the rotation out of the engine to the rest of the powertrain. Lubrication is essential for the components involved; therefore a reservoir of oil is constantly circulated and applied. The reservoir is sometimes integrated into the crankcase or, in the case of two-stroke engines, the oil is mixed in with the fuel as it passes through the crankcase.

29 Directive 2009/40/EC amended by Directive 2010/40/EC. URL http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2009L0040:20100728:EN:PDF

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When combustion takes place in the cylinders, some fully, partially or unburned emissions can be forced past the piston rings, into the crankcase, where they will mix with the oil. Though not an issue for two stoke engines, which constantly feed these gases back into the combustion chamber, for four stoke engines it is an issue. These mixed gases and the general warming of the crankcase area, creates an over-pressure, if not controlled when it escapes it will take the untreated gases with it into the atmosphere. These gases are termed crankcase emissions. Crankcase emissions are historically significant, being the first area of vehicle emissions to be legislated (California USA, in 1961). Regulation (EU) 168/2013 requires that “Crankcase emissions shall not be discharged directly into the ambient atmosphere from any vehicle throughout its useful life”30. In contrast to other emission test types, this does not attempt to detect the gases, which in a modern engine would be very low and could emanate from multiple areas of the engine. Instead the test involves checking if the method employed to transfer the gases within the crank to the combustion intake, is creating the intended state for it to do so. There are two test methods; one monitors the crankcase pressure of a running engine, to be sure it is below ambient, and the second lightly pressurises the crankcase of a non-running engine to check that seals are functioning correctly. The tests will first be required for the larger categories of vehicles; L3e, L4e, L5e and L7e in 2016, followed by the remaining smaller category L1e, L2e and L6e vehicles in 2017. There is no difference in this test between conventional engines and hybrids of any fuel type (as shown in Annex C). Type 4 test: Evaporative emissions Regulation (EU) 168/2013 states that, subject to the findings of any commissioned studies, the evaporative emissions should be tested. There are three tests; the Sealed Housing Evaporative Determination (SHED) test for the entire vehicle, base permeability testing of the fuel tank as is currently required and permeation testing of the fuel tank and fuel tubing. The SHED test consists of placing the vehicle in a sealed room for a length of time and the hydrocarbon vapours permeating into the atmosphere are measured in mg/test. The permeability and permeation testing takes the fuel tank and fuel tubing and measures the flow of vapours through its surface in mg/m2/day. The specifics of the SHED test have yet to be published; it may follow the current test as used for motorcycles in California as laid down by the California Air Resource Board (CARB). The test is performed on PI (positive or spark ignition) engines running on gasoline, gasoline blends and ethanol. This is due to the greater volatility of these fuels, commonly used in PI engines. The SHED test will come in force first with the step to Euro 4, and then the permeation testing may follow in the third step to Euro 5, if proven cost effective in the environmental effect study. To prevent evaporative emissions, vehicles employ a system which feeds the fumes from the tank back into the engine’s air intake for burning as usual. While the vehicle is not running these fumes are soaked into a carbon canister, which later has air flowing through it to release the fumes when the engine is stared again. For Hybrid vehicles this may pose a problem, as the engine may not be used as often, and so not burn the stored fumes. Once the carbon canister is saturated the fumes

30 Regulation (EU) 168/2013, Annex V, Environmental tests and requirements, page 113

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will again begin to disperse into the atmosphere. Hybrid car and van (M1 and N1 category vehicles) manufacturers employ systems such as a flexible bladder within the fuel tank to reduce the available air volume above the fuel (into which the fumes evaporate), however these reduce the fuel tank volume31. Type 5 test: Mileage accumulation (Durability) To measure the durability of emission abatement parts (such as the catalytic converter, lambda sensor, etc.), the vehicle is driving on a track, road or chassis dynamometer for a defined test distance that depends on the vehicle category. The vehicle would follow either the US EPA Approved Mileage Accumulation (AMA) or the Standard Road Cycle for Light Category Vehicles (SRC-LeCV) durability driving schedules. At multiple intervals type 1 emissions tests would be carried out to identify the deterioration trend of the pollution control devices. To pass, the vehicle would have to keep within its defined tail pipe emission limits up to the prescribed mileage. However, due to the cost implications of driving the full test distance, other options are available to perform an accelerated durability test. The following are the three options on how to perform the test (see Regulation 168/2013, Article 23, section 3 for more information): • Actual durability testing with full mileage accumulation, or • Actual durability testing with partial mileage accumulation, where the test vehicle shall physically

accumulate a minimum of 50% of the full test distance and multiple emissions tests are used to extrapolate the results up to the full test distance, or

• Mathematical durability procedure, where no mileage in accumulated, instead each emission constituent from an initial type 1 test is multiplied by an established deterioration factor (DF). The DFs change with the Euro emission steps to take account of the increased number of pollutants measured and differences between PI and CI engines.

For hybrid vehicles, the test is generally performed in the same manner. Mileage accumulation is performed in the vehicle’s operating mode that is automatically set after turn on of the ignition key. For vehicles capable of off-vehicle charging, the batteries may be charged twice a day during mileage accumulation. When emissions measurements are made using the type 1 test, the additional test requirements for hybrid vehicles must be taken into account. Type 7 test: Measurement of carbon dioxide emissions and fuel/energy consumption and a test for electric range The type 7 test comprises of a selection of tests, related to consumer data on running costs and environmental damage. These measure: CO2 emissions, fuel consumption, energy consumption (such as battery or compressed air) and electrical range. The CO2 and fuel/energy consumption is measured at the same time as the type 1 test. However the electrical range, which is performed on all HEV, EV and those grouped with EV, requires a separate test. CO2 is measured directly from the collected and diluted emission sample bags. However fuel consumption is calculated by balancing the chemical equation from all the measured carbon based emissions, together with the known composition of the original fuel; the “carbon balance” method. Fuel consumption used to be measured by monitoring the fuel flow from a separate measuring vessel. However, in modern vehicles the on board electronics sometimes interpret the bypass as a fault, preventing the vehicle from functioning as required.

31 The 2010 Toyota Prius Hybrid Got a Bladderectomy. 7th July 2009, accessed 9th July 2013. http://www.treehugger.com/cars/the-2010-toyota-prius-hybrid-got-a-bladderectomy.html

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This proposed electric range test follows the same method from the current legislation. However, it would permit the testing of a greater range of vehicle propulsion types. Type 8 test: On-board diagnostics Regulation (EU) 168/2013 states that, subject to the findings of any commissioned studies, that an on-board diagnostics system (OBD) should be required in vehicles, in order to facilitate efficient and effective repair of a vehicle. This serves the twin pillars of environmental protection and functional safety, by diagnosing potential faults in various key vehicle systems, both those controlling vehicle emissions and those relevant to accident avoidance. For emissions, an OBD monitors and reports, via a standardised connector and communication protocol, the status of the vehicle to be read during maintenance and also flashes up a tell-tale; the malfunction indicator light (MIL), to the driver that there is an electric / electronic problem with the vehicle in the case of OBD I, and also in the case of OBD stage II; if it has detected a situation that may indicate excess emissions are being produced. The Type 8 testing uses aged parts to ascertain whether the system activates this warning appropriately, via a special Type 1 test procedure. It is thus an emissions verification procedure, and just one part of a much wider OBD concept. Both environmental and functional safety aspects will make part of the on-board diagnostic concept as envisaged to become applicable for the heavier L-category vehicles. The implementation dates for specific categories are shown in the following table, the steps are cross referenced to those in the table below. Table 3.8: Implementation dates of OBD for new vehicle types, Regulation (EU) 168/2013, Annex IV

Category Step OBD stage

L3e, L4e, L5e-A, L7e-A 1 2016 I

L6e-A 2 2017 I

All from L3e to L7e 3 2020 I

L3e, L5e-A, L6e-A, L7e-A 3 2020 II

Reference Fuel As mentioned in section 3.2, there are many additional fuels which would, if the REPPR is enacted as currently drafted, give a consistent testing method. Previously, alternative fuels would be tested at the discretion of the approval authority. In addition the specifications of the two fuels which are stated in the current legislation; petrol and diesel, have been changed to E5 and B5, which more closely match the fuels now prevalent for sale in Europe.

3.3 Future legislation

Further development of L-category legislation is underway at an international level within the UN EPPR informal working group32 (IWG). The work of this group is in its very early stages. It is envisaged that a similar line of updating the scope as being developed within the EU, in addition to developments being done in China, India, Korea, Japan, USA and other regions working with the UN ECE.

32 Environmental and Propulsion Performance Requirements of L-category vehicles (EPPR). URL https://www2.unece.org/wiki/pages/viewpage.action?pageId=5800520

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As the name suggests, the group will cover Environmental and Propulsion Performance Requirements (EPPR). ‘Environmental requirements’ regard the gaseous and particulate emissions from a vehicle’s propulsive and fuelling system both when in use and not in use, and the ‘Propulsive requirements’ regard the motive power and speed capabilities of the vehicle. The propulsive requirements are important when assigning a vehicle to a specific category, and consequently which environmental tests it will perform. The group’s mandate33 indicates that the main activities the group propose to focus on are revising or establishing environmental performance verification for all the above-mentioned test types. The group will cover conventional vehicles equipped with combustion engines only as well as advanced concepts such as electric and hybrid electric powertrains. All possible fuels will be taken into consideration: petrol, petrol-ethanol mixtures, diesel, biodiesel but also gaseous fuels such as CNG, LPG, Hydrogen and their blends. In addition rules and test procedures to measure power and torque and maximum design vehicle speed will be developed. Furthermore, it will be assessed whether the classification of the vehicles requires refinement. There have already been 3 meetings of the EPPR IWG, as well as additional conference calls to develop the mandate, roadmap and terms of reference. The dates and meeting summaries are listed below. Table 3.9. EPPR-IWG previous meeting

Session, location and date(s) Meeting summary

December 2012 Publicising study, Email to stakeholders

10 January 2013 Questionnaire published by Ecorys and TRL

18 January 2013

GRPE (65th session) & EPPR

(1st session) at Geneva

1st meeting of the L-EPPR group, review among others: Rules of Procedure

(RoP), Terms of Reference (ToR) and Draft roadmap

12 – 15 March 2013 WP.29

(159th session) at Geneva

Progress report submitted to WP.29

25 – 26 April 2013: EPPR (2nd

session) at Brussels

Review: RoP, ToR, Mandate, Roadmap Discuss: Configuration of new

legislation

Between 2nd – 3rd EPPR Conference calls to discuss ToR, RoP, Mandate and roadmap

4 – 7 June 2013: GRPE (66th

session) & EPPR (3rd session)

Adoption of RoP, ToR & roadmap

The next steps for the group include: • Autumn - Winter 2013: EC to publish draft proposals of all tests under development • January 2014: Identify areas of work Present draft Guide to GRPE for comments and input • 2014-2016: Adopt new and/or amendments to UN Regulation(s) and GTR(s) under both 1958

and 1998 agreements; • 2016 Regions accede to agreed updated legislation

The upcoming meetings together with their provisional agenda items are listed below:

33 [Informal Document WP.29-160-18. 160th WP.29 session. 25-28 June 2013. http://www.unece.org/fileadmin/DAM/trans/doc/2013/wp29/WP.29-160-18e.pdf]

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http://www.unece.org/fileadmin/DAM/trans/doc/2013/wp29/WP.29-160-18e.pdf

Table 3.10. Upcoming EPPR-IWG meetings

Session, location and date(s) Provisional agenda

Audio-Web conference, 13

September 2013

Review roadmap and project plan, discuss the practical arrangements for 4th

EPPR meeting in Pune (India)

Pune, India, 8 – 9 October

2013 EPPR (4th session)

Submit EC’s proposals for tests, other items to be discussed in the preceding

audio-web conference

12 – 15 November 2013:

WP.29 (161th session)

Adoption of GRPE decision and progress report

January 2014 EPPR (5th

session)

To be decided in the 4th session

It is within the mandate of the EPPR informal group to complete the majority of the work by 2016. At which point it is the intention of the EC to accede to and replace its existing legislation with reference to the new, internationally defined legislation, provided it does not reduce regulatory stringency from that which is currently being developed.

3.4 Summary

From the assessment of the current and legislation under development, the following key issues have been identified in connection with hybrid and other non-conventional powertrains: • Current legislation

- Hybrid vehicles are only considered in testing for the larger vehicles of the L category - EV, Pedelecs (human electric hybrid cycles), etc. are not tested, nor is there an exception to

indicate whether they can be approved without requiring emission testing - Dual fuel, multi-fuel, and non-conventional fuels are not catered for - The reference fuels used for testing are not representative of current fuels used by the fleet

• Legislation under development - Most powertrains will be accounted for irrespective of the category of vehicle - Greater harmonisation between sub-categories, fuel types, and propulsions - Increased number of emission sources tested - The reference fuels for petrol and diesel engines (E5 and B5) have been updated from those

used by the current legislation The following lists summarises the changes to each of the emission test types being developed for L-category vehicles by the EC (excluding noise emissions). • Type 1 test: Verifying the average exhaust emissions at ambient conditions;

- The amended WMTC test as defined in UN GTR No 2 will be used - The test methods will be harmonised between sub categories - Increased number of parameters will be measured - Specific test methodology for HEVs, including testing at full and minimum traction battery

levels • Type 2 test: Measuring carbon monoxide at idling speeds and smoke opacity test (applicable to

CI vehicles only); - The test methods will be harmonised between sub categories - Single test for all sub categories, testing both idle and high idle - Free acceleration test for CI - Test performed on ICE vehicles including hybrids and CA - Specifically references to Directive 2009/40/EC on the link with this test and PTI testing

• Type 3 test: Verifying emissions of crankcase gases;

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- Testing will be added - No difference with test in respect to fuel or HEV

• Type 4 test: Determination of evaporative emissions; - Testing will be added - Test performed only with vehicles encompassing PI engines (including HEVs), as these

typically use fuels with a high volatility • Type 5 test: Verifying the durability of pollution control devices;

- Testing will be added - The test schedules include the use of the type 1 test, where specific differences to the test

for HEVs are defined • Type 7 test: Measurement of carbon dioxide emissions and fuel/energy consumption and a test

for electric range - Testing of electric range will be expanded from HEVs to also include EVs and other vehicles

grouped as EVs • Type 8 test: On-board diagnostic test

- The requirement to fit such systems and testing of their functionality will be added Another issue is the terminology used. For instance in the L-category legislation electric vehicles are termed EV, however in the draft WLTP; BEV (battery electric vehicles) and PEV (pure electric vehicles) are used. This could possibly be an area of confusion if used in consumer information.

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4 Heavy duty passenger and commercial vehicles (M2+ and N2+): Review of existing legislation, Regulations and standards

4.1 EV & HEV Technologies

The appropriateness of EV or HEV technologies in the heavy duty vehicle sector is highly dependent upon the vehicle duty cycle. In long-distance, heavy haulage, for example, there is very little scope for them, whereas in applications such as city buses, refuse lorries and local delivery operations, some degree of electrification/hybridisation is feasible (Atkins, 2010). Technologies have evolved accordingly over recent years. Pure electric-only heavy duty vehicles are rare, primarily because of the limited energy density of current battery technologies. This means that to equip a vehicle with batteries sufficient to power it over a reasonable distance, there is likely to be a serious loss of available payload (both by weight and volume). That said, such vehicles can find niche applications, e.g. where near-silent operation is desirable (such as for out-of-hours deliveries or working in sensitive residential areas). Smith Electric Vehicles, for example, produce the Newton chassis-cab truck, available in gross vehicle weight (GVW) options of between 7,500 kg and 12,000 kg. Range is claimed to be up to 240 km, and running costs less than €0.05 per km. The smaller Edison model (GVW 3,500 kg – 4,600 kg) is sold in chassis cab, panel van and minibus forms, and has a claimed range of up to 180 km, and running costs from €0.03 per km. In June 2013, Smith Electric announced that it had to date produced 700 such all-electric vehicles, which together had journeyed over 8 million kilometres on roads around the world. All-electric buses are also quite rare, but have found application in specific uses such as hotel/airport shuttle services. The OREOS 4X, for example, is a minibus with an overall capacity of 49 people, including 25 seats. Its range is claimed to be 150 km. In France, these all-electric buses are claimed to provide 95% CO2 savings compared to conventional diesel equivalents. As mentioned above, on-board, battery-electric, energy storage options are not feasible, with current technologies, for long-distance, heavy haulage operations involving mostly relatively high, constant speed motorway running and very little low speed, stop-start operation. Options for electrification still exist here, however. Siemens, for example, are developing their “eHighway” concept which involves electricity being delivered constantly to motorway freight vehicles via overhead catenary lines. Hybrid vehicle technologies are becoming increasingly common in heavy duty vehicle sectors, particularly in urban applications such as city buses and utility vehicles such as refuse lorries. These applications typically involve relatively low speed operations with frequent stops and starts. Parallel and series diesel-electric hybrids are already well established in many such markets, with plug-in hybrids and fly-wheel systems also becoming available. In London, for example, diesel-electric hybrid buses were first introduced in 2006, and there are now approaching 500 such buses (both series and parallel) in use in the city. Fuel savings of around 30% compared to conventional diesel buses on the same routes have been observed. Trials of all-electric buses and those using inductive charging systems are planned for the period up to 2021/22.

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In Europe manufacturers such as Iveco, Mercedes and Renault have (parallel) hybrid trucks available to customers today, at least for the medium-duty sector of up to around 26 tonnes gross vehicle weight. Fuel consumption savings of around 15-20% are claimed, alongside other benefits such as reduced noise when in electric-only mode. Single deck, fuel-cell buses have been on trial in various cities around the world, including many in Europe via the CUTE project (Clean Urban Transport for Europe). These work by converting hydrogen into electrical energy. These are currently very expensive, however (up to 6 times the cost of a conventional bus), but CO2 savings can be over 90% if the hydrogen is produced via the electrolysis of water using very low carbon electricity). Other (non-electric) forms of hybridisation are also being used and/or developed, including flywheel (kinetic energy storage) systems and hydraulic (accumulator) technologies.

4.2 Recent regulatory developments

In May 2013, the UNECE GRPE Informal Group on Heavy Duty Hybrids (HDH) produced its first draft of an amended version of Global Technical Regulation No. 4 (GTR n° 4) – test procedure for compression-ignition (C.I.) engines and positive-ignition (P.I.) engines fuelled with natural gas (NG) or liquefied petroleum gas (LPG) with regard to the emission of pollutants. This draft aims to widen the scope of GTR No 4 to include HDH vehicles and to introduce two alternative test procedures for such vehicles; referred to as the Hardware-In-The-Loop (“HILS”) method and the “powertrain” method. The following text describes the evolution of this draft, based on a review of the many documents published on the web pages of the GRPE Informal Group (HDH). This HDH Informal Group was established in 2010, and under the chairmanship of the European Community currently (June 2013) expects to complete its work in early 2014, ready for GRPE adoption in June 2014 and WP.29 adoption in November 2014. The objective of the Informal Group was to establish an amendment to GTR No 4 (WHDC) with respect to pollutant emissions and CO2 emission from heavy duty hybrid vehicles under the 1998 Global Agreement. The original (2010) justification for this work mentioned that “greater fuel efficiency and the reduction of CO2 emissions are becoming an increasingly urgent issue in view of global warming and surging petroleum prices. Hybrid vehicles (HVs) are recognized as one solution for achieving lower emissions and increased fuel efficiency. Consequently, a widespread introduction of HVs has taken place during the last years, primarily for passenger cars. But also commercial vehicle manufacturers have introduced, or announced the introduction, of several hybrid concepts for urban, delivery and extra-urban operation. While testing of passenger car hybrids is covered by ECE R 83, no provisions exist today within the ECE framework for heavy duty hybrids.” With GTR No 4, a globally harmonized emissions testing procedure (for conventional commercial vehicles) has been established. Traditionally, emission testing of conventional heavy duty vehicles involves engine testing, and the certified engine can then be installed in any vehicle independent of its application. Contrary to conventional vehicles, emissions testing and certification of HVs disregarding the vehicle application is not the optimal technical solution. Since engine speed and load cycles of HVs are quite different from those of conventional powertrains, it is necessary to incorporate vehicle and mission related elements into the certification procedure.

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If such an approach is used, engine technologies and engine calibrations can be tailored to the hybrid applications, allowing engine technology to be optimized for HV operation, keeping the overall emissions performance equal to conventional engines and fully optimizing fuel consumption, CO2 emissions and product costs. The proposal aimed to provide an engine based test procedure and harmonized technical requirements for pollutant emissions and CO2 certification of HVs (including electric hybrids, hydraulic hybrids, plug-in hybrids, range extenders and start/stop solutions). The focus has been on the HILS (Hardware-in-the-Loop) approach, which starts from a vehicle cycle and simulates powertrain and vehicle components to result in a HV specific engine cycle for emissions testing and measurement. This allows using the test cell environment, data evaluation procedures and emissions calculations already specified in GTR n°4. Following pressure from some, in 2011 the HDH Informal Group extended its mandate to also cover “powerpack” testing, which is the testing of various components of the hybrid power system on an engine test cell. At the outset of its work, the HDH Informal Group identified the following existing international regulations and standards: • Japan - Kokujikan No.60 of 30 June 2004, “Measurement Procedure for Exhaust Emission from

Electric Hybrid Heavy-Duty Motor Vehicles” and Kokujikan No.281 of 16 March 2007, “Measurement Procedure for Fuel Consumption Rate and Exhaust Emissions of Heavy-Duty Hybrid Electric Vehicles using Hardware-In-the-Loop Simulator System”

• SAE Standard - SAE J 2711 "Recommended Practice for Measuring Fuel Economy and Emissions of Hybrid-Electric and Conventional Heavy-Duty Vehicles"

With funding from OICA and others, the Informal Group appointed a consortium of research institutes to support its work – TU Graz, TU Vienna (IFA), Chalmers University and TRL. In 2011, this consortium was given six main tasks: • Task 0 – Co-ordination • Task 1 – Investigation and modification, if applicable, of the HILS model and interface • Task 2 – Investigation and modification, if applicable, of the HILS component testing • Task 3 – Extension of HILS to non-electrical hybrids • Task 4 – Inclusion of PTO operation, which normally takes place outside the test cycle • Task 5 – Development of WHVC weighting/scaling factors to represent real world vehicle

operation

The results of the research were presented to the Informal Group in March 2012, and can be summarised under each of the technical tasks (Tasks 1 – 5 above) as: Task 1 - In general, the Japanese HILS model provides a good basis but needs to be refined for establishing a global regulation, e.g. regarding gradients and vehicle data sets; Task 2 - The component test procedures laid down in the Japanese regulation are common test procedures that can be adapted for a global regulation and are considered to provide correct input data to the simulation models. A component library is proposed and thermal effects need further investigation; Task 3 - Non-electric hybrid powertrain topologies fit well into the same categories as for electric hybrid powertrains. No major modifications to the HILS model are needed, since non-electric components/subsystems have the same purpose as their electric equivalents;

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Task 4 - Inclusion of PTO operation is not recommended for criteria pollutants due to the minor influence of PTO load on brake specific emissions and since it would not be in line with the test procedure for conventional engines; Task 5 - A methodology to calculate WHVC weighting factors to represent real world vehicle operation was developed that is applicable to all combinations of test cycles and vehicles. The research then entered a validation phase, initially with the development of driver models, a first proposal for thermal-effect models and the development of a component library, as well as validation by software-in-the-loop-simulation (SILS). Validation with real hardware (one serial and two parallel hybrid vehicles) began in May 2013, with completion expected by September 2013. Based on the research results to date, and the other evidence presented to it, in March 2013 the HDH Informal Group agreed to appoint a drafting group, who would develop a heavy duty hybrid test procedure as an amendment to GTR n° 4, by introducing a new Annex 8, which:

a. Includes the HILS method based on Japanese regulation Kokujikan 281 and input from HDH development;

b. Includes a powertrain method based on the US-EPA procedure At its most recent meeting (June 2013), the Informal Group also discussed a suggestion from OICA that plug-in hybrids should be included, and the idea that CO2 results from HILS could be used as input to regional CO2 regulations. This latter suggestion results from the lack of a WP.29 mandate for CO2 regulation for conventional heavy duty vehicles and thus the inappropriateness for UNECE to develop such a regulation just for HDH vehicles, while allowing HDH to develop the procedure for CO2 determination. The topic of OEM specific models being allowed, and how they should be validated, verified and approved is also under on-going discussion. Further HDH meetings are planned for October 2013 and January 2014.

4.3 Summary

• A wide range of electric, hybrid-electric and non-electric hybrids are available or being developed for heavy duty vehicles (trucks and buses). The applicability of particular technologies is highly dependent on the vehicle’s likely duty cycle.

• An Informal Group on Heavy Duty Hybrids (HDH) was established by GRPE as part of the UNECE regulatory development process in 2010. This Informal Group’s work is on-going, with completion expected early in 2014.

• The Group has commissioned new research and reviewed existing (Japanese) legislation and international (SAE) standards. It is currently working towards drafting an amendment to Global Technical Regulation No. 4 for adoption by GRPE and WP.29 in 2014.

• The first draft of that amendment was published in May 2013, introducing a new Annex 8 and allowing for both a Hardware-in-the-Loop Simulation (HILS) procedure (based on existing Japanese legislation but modified in the light of the research findings) and, as an alternative, a powertrain procedure (based on the US-EPA procedure).

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5 Review of stakeholder requirements

5.1 Introduction

In the previous chapters the existing legislation was reviewed to identify the current tests to be performed and the parameters to be measured with regard to the type approval of EVs and HEVs respectively. In the assessment of suitability of new test types not only technological considerations can be incorporated, but also the information these tests generate to consumers can be taken into account. EV/HEV utility indicators play a role in how consumers choose vehicles. These parameters could be based on standardised test procedures and can be presented to consumers in different forms. This chapter analyses the requirements of consumers, the automotive industry and other relevant interest groups. Consumer purchasing behaviour of cars, vans and motorcycles and consequently demand for these vehicles is an important driver for the penetration of a new technology in the market. At the same time, industry stakeholders may be affected when considering amendments to the current type-approval procedures. Thus, for scoping the key issues and views from stakeholders when considering revisions to the existing type-approval test procedures for EVs and HEVs, two questions are central: • What are the key views and considerations from an industry’s perspective (automotive

manufacturers, suppliers, interest groups)? These views and considerations may for instance relate to technological developments, any pros and cons of revising type-approval test procedures, test-procedures that the industry applies on a non-regulatory basis, and what type of vehicle attributes should be provided to consumers.

• What are the key views and considerations from a consumer perspective (consumer organisations, individual consumers, interest groups)? More specifically, which information on vehicle attributes is desired by consumers when purchasing a new vehicle so as to allow consumers a fair trade-off and overcoming current uncertainties associated with hybrid-electric and electric vehicles.

A review of stakeholder (consumer and industry) requirements has been part of this project. The parameters have been examined using three methods: (1) a literature review, (2) a stakeholder consultation as well as interviews, and (3) a consumer survey. The results of this examination are described respectively in section 5.2 to 5.5. The chapter is completed with a summary section (section 5.6).

5.2 How consumers choose vehicles

Introduction Consumers choose vehicles by taking many aspects into account. They differentiate between different makes and models, what the vehicles have to offer and make choices that maximize their utility when compared to other available makes and models of interest (Garcia, 2007). Factors which influence vehicle choice comprise vehicle related factors, e.g. price, fuel economy,

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consumer-specific demographics, e.g. age, household size, and finally psychographics, e.g. lifestyle, attitudes, personality. A number of parameters that play a role in consumer decisions is provided through type-approval legislation. As shown in the previous chapters, parameters in standardised test procedures are primarily defined by regulators in view of their relevance in meeting technical (environmental and safety) standards. All manufacturers are for instance obliged to follow common test procedures to determine the fuel economy levels of different vehicle models, which can consequently be used for advertising. Currently, hybrids and electric vehicles still represent a tiny fraction of total vehicles on the road, especially for M and N category vehicles. Among L-category vehicles in particular electric vehicles are ahead (mainly mopeds and cycles). Worldwide, there were over 180,000 electric cars late 2012, representing 0.2% of the worldwide stock (IEA, 2013). Growing environmental concerns among consumers, environmental regulation, volatility of fuel prices, and depletion of oil reserves, combined with an increased offer of EV/HEVs is expected to translate into an increase in demand for EVs, although uncertainties exist towards the future of EV/HEV. Some say that the automotive industry will likely see the strongest changes in customer buying preferences in its 100-year history over the next ten years (Deloitte, 2009). Not all specific parameters that are relevant for HEVs and EVs are to date regulated. As a result information that is provided is not harmonised or standardised and can be based on different measurement methods. In the case of the hybrids / electric vehicles, current standardised test procedures are still mostly based on procedures for conventional fuelled cars as they have dominated the market for many decades, which do not always fully address the characteristics and risks of (P)HEVs and EVs.

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Text box: Car labelling and EV/HEVs

Even though it is not within the scope of the present

study, it is clear that the provision of easily

understandable information on the environmental

parameters of vehicles is important in influencing the

decisions of end-users. This could be done by

information tools like guides, posters/ displays and

promotion literature but a commonly used example of

presentation of the parameters is by labelling.

Car labelling was first introduced in the Directive

94/1999 (EC, 1999), which related to the availability of

consumer information on fuel economy and CO2

emissions for new passenger cars. The purpose of

the Directive was to properly inform prospective

consumers on their options (for buying or leasing) regarding the aforementioned criteria. The car labelling

systems in use in the different Member States differ in their presentation although they follow a similar

underlying principle. In Europe, unlike the US, no specific labels exist for EV/HEVs.

Car labels for EV/HEVs in the US

The National Highway Traffic Safety Administration (NHTSA) and the Environmental Protection Agency (EPA)

have issued requirements for a fuel economy and environment label. The label provides expanded information

to American consumers about new vehicle fuel economy and fuel consumption, greenhouse gas and smog-

forming emissions, and projected fuel costs and savings. For advanced technology vehicles (hybrids and

electric vehicles) the labels include:

• Driving Range: Identifies how many miles EVs (electric vehicles), PHEVs (plug-in hybrid electric

vehicles), FCVs ([hydrogen] fuel cell vehicles), and CNG (compressed natural gas) vehicles can

drive before recharging or refuelling.

• Charge Time: Identifies the amount of time it takes to charge EV and PHEV batteries.

• Different Modes: Some vehicles, such as PHEVs, may have two or more different operating modes –

such as all-electric, blended gas and electric, and gasoline-only. The labels will provide certain

information for different operating modes.

• Fuel Economy: The label shows fuel economy for advanced technology vehicles in miles per gallon

of gasoline-equivalent (MPGe). A gallon of gasoline-equivalent means the number of kilowatt-hours

of electricity, cubic feet of CNG, or kilograms of hydrogen that is equal to the energy in a gallon of

gasoline.

• Energy Consumption Measurement: Fuel consumption is expressed as a unit of fuel purchased

(e.g., kilowatt-hours) per 100miles.

Figure: Examples of labels for EV (left figure) and PHEV (right figure)

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Car attributes The vehicles attributes that are involved in the decision making process of the consumers can be distributed into three categories: • Technical parameters • Financial parameters • User parameters Technical parameters are the prime target of standardised testing procedures. They do reflect technical aspects that can be addressed by non-market based instruments such as standards (e.g. focusing on efficiency-improvements). As such they encompass a wider range of aspects, not limiting to the technical characteristics. As a result, existing consumer studies cover only a limited part of the technical preferences in combination with financial and social aspects. Hence, some important aspects of the technical-oriented choices, not included literature, have been retrieved by direct stakeholder and expert feedback, as well as the consumers themselves via a questionnaire, in order to define their preferences when purchasing a vehicle. This category distinguishes within the technical specifications for EVs-HEVs provided by the vehicle manufacturer, the environmental effects and the technical characteristics which do not subject to the manufacturer (e.g. the frequency of recharging points). The financial parameters can be distinguished according to various costs and fiscal measures defined throughout the lifetime of the vehicle. Costs can include variables such as capital cost, operation (fuel costs, battery charging costs) and maintenance (battery change) costs. They may also relate to the depreciation and resale value of the vehicle. Financial parameters are not part of the present study as they are not related to testing procedures and may differ considerably by country. In this sense, many financial parameters are a country-specific derivative of the technical parameters that are central in this study. Nonetheless, one should take into account their significance in consumer decision making and the fact that they could be the object of market based policy interventions (e.g. fiscal policy, or subsidies). That is the main reason that the financial parameters were included in the questionnaire. The user parameters are those elements which encompass both technical and non-technical characteristics which do not belong in the previous two categories; including parameters related to user friendliness. On the technical side, this category refers to information which are not defined by the vehicle manufacturer like the availability of recharging points. In addition, the user parameters incorporate characteristics such as the vehicle design or the vehicle brand which appeal more to their personal preferences. Points of particular interest at the analysis In analysing the most relevant parameters for consumers it is important to note three key issues. Firstly, whereas a parameter may be relevant there are different degrees of importance in information. Not all information is equally significant. This is especially useful so as to avoid an information overload to consumers. Secondly, it is important to take a grasp of the actual consumer’s response to different kinds of vehicles. Both EV and HEV represent novel technologies in comparison to conventional cars. In a worldwide study from Accenture (2011) consumers indicate a lower preference for EV than for HEV which is mainly related to the lower range (and related uncertainty) for EVs. Finally, consumer decision making is not a homogeneous process but is strongly influenced by consumer characteristics such as financial state/ income, age, gender and individual preferences.

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On top of that, other external factors (e.g. policy measures or the specific environment in which the consumer lives) can play a role. As an example, Weinert et al. (2008) refers to shift towards electric two-wheelers (E2W) adoption in China, which is not only driven by cost and technical characteristics but also the local policy support to E2Ws, poor bus public transit service and the motorcycle bans in some areas. The following sections show the results of the three methods applied in determining stakeholder requirements: (1) a literature review (section 5.3), (2) a stakeholder consultation as well as interviews (section 5.4), and (3) a consumers’ survey (5.5). The sections focus to a large extent to the decision making process of consumers.

5.3 Consumer preferences based on literature

In this section first an overview is given of indicators that are related to specific characteristics of EV/(P)HEV vehicles, This is followed by a summary of the most important literature findings on consumer preferences and relevant parameters. Overview of most relevant distinguishing indicators As indicated earlier EVs, HEVs and PHEVs have different characteristics, which, based on their individual technologies, may suggest that different information becomes relevant to consumers or that not all information has the same weighting factor. For example, the driving range will have different weight for prospective EV and HEV users. This section studies the literature for consumers in order to indicate the parameters which are most relevant regarding the EVs/ HEVs. The review of EV and HEV vehicles is differentiated for the main technologies which can be distinguished in hybrids (HEV), plug-in hybrids (PHEV), and electric vehicles (EV) and electric two-wheelers (ETW). Most research has been conducted in the field of passenger vehicles, in particular in the US (California) and Canada. Limited studies have been conducted on the consumer preferences and requirements for the L-category vehicles. Plug-in Hybrids Vehicles and Hybrid Electric Vehicles indicators Many studies introduce the “effectiveness” term as an PHEV/HEV indicator. Bradley & Quinn (2010) and Zhang et al. (2011) use the ratio of the distance travelled under charge-depleting mode to the total distance travelled, including charge-sustaining mode in order to evaluate the effectiveness of the vehicle powertrain in PHEVS. Bradley & Quinn (2010) describe the effectiveness of PHEVs using utility functions for a specific PHEV model, for both charge-depleting and charge-sustaining states Their study concludes that the utility functions are very sensitive in the cases of consumer battery charging behaviour, the vehicle age and the vehicle annual distance driven. On the contrary, the utility function presents no sensitivity regarding the vehicle class, the vehicle fuel economy and the driver characteristics. In terms of the non-significant indicators, it is suggested that the driving patterns either do not differ between different cases or are not a strong function of the characteristic under analysis. Zhang et al. (2011) base also their conclusions on the electrification range, i.e. the ratio between charge-depleting and total consumption modes. Furthermore they conclude to the following findings relating to recharging capabilities and fuel reduction: • Increasing the number of recharging points, besides home recharging, can save up to 35

percent of fuel

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• Increasing the charging power at the recharging points (home, work etc.) can reduce the fuel consumption up to 20 percent (using all available recharging points)

• The charging hours influence significantly the power grid. The authors here refer to the home charging option. Immediate home charging (from 6 to 9 pm) results in an electricity demand peak averaging less than 1 kW per vehicle. Increasing the charging power would undesirably shift the peak hour closer to the existing grid power.

Finally, Zhang et al. (2011) refer to the difficulty and the importance of measuring the cold-start emissions for PHEVs/ HEVs. Electric Vehicles indicators In their article Brown et al. (2010) analysed the standards for fostering the EVs in terms of electrical systems, batteries and recharging infrastructure as well as consumer and vocational environments. They highlight the areas that standardisation is missing and is crucial to be undertaken and commuted to end-users34. One main aspect of the article is the standards in technological advancement of batteries (and battery components) which should fall under compatibility and international constraints. In terms of technology, EVs have been investigated from the consumer’s perspective in Offer et al. (2010). The main attributes of performance were peak power (acceleration), average power (cruising efficiency) and energy density (range). According to this study, an EV can deliver peak and average power but is has a relatively low energy density. The EV range is dependent on vehicle efficiency. If this is improving (e.g. decreasing ancillary loads, vehicle mass and aerodynamic characteristics etc.), the range increases. Finally, in order to optimise the environmental benefits of the EVs, standards should be amended so as to ensure that the additional requirements for electricity generation originate from clean and low-carbon sources (Brown, 2010). That is because well-to-wheel emissions of electric vehicles depend on the power grid generation mix (Offer et al., 2010). Electric Two-Wheelers indicators Weinert et al. (2008) among other driving forces refer to the improvement in battery technologies and, in general, E2W technologies, as the main parameters of their adoption in China; more specifically the improvements have been noticed in the battery lifetime (160%), the energy density (30%) and the motor efficiency (60%). Besides the amendments in battery technologies, the performance of E2Ws has been boosted in terms of increasing size, power and vehicle speed. These characteristics have contributed in the E2W adoption also for consumers using them for longer distances or mountainous areas. Furthermore, ADB (2009) describes the parameters which influence the adoption of E2W in India and Vietnam. This research mainly relied on fiscal indicators, but it also included vehicle characteristics such as acceleration, top speed, transmission (automatic or manual) and carrying capacity. In both countries, E2W are outperformed by standard 2W on all of these indicators. Furthermore, the study concluded that, as a consequence of image problems and disfavour (which are mainly due to poor early experiences), gasoline vehicles are preferred over E2W. Relevant criteria from a market/ consumer perspective Whereas the previous section defined the most relevant distinguishing indicators that stem from the specific characteristics of alternative vehicles, this section describes the criteria which are relevant

34 The article refers to multiple updates for standards including infrastructure demand for large-scale resources.

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to consumers in their purchase decision of hybrid and electric vehicles as found in existing sources. Additional criteria can be found in the next paragraph (5.4), based on stakeholder input. A global automotive market research by Capgemini (2008) indicates that the four most important considerations in car purchasing choice, being reliability, safety, fuel economy and price, are consistent in both developing and mature markets (see figure below: please note that the data is for cars only). Beyond that, however, there are some significant differences. For example, all factors matter more in emerging markets, because of consumers’ lack of experience in buying cars in countries such as China, India and Brazil. Figure 5.1: Importance of factors in consumers’ choice of vehicles, Capgemini (2008).

The LowCVP (2010) study indicates that when asked what factors were most important when purchasing their current car, results from the survey show that ‘fuel economy/running costs (‘miles-per-gallon)’, ‘size/practicality’, and ‘vehicle price’ are the three factors consumers consider most important during the decision making process (note: these are presumed to be different for the other vehicle categories). ‘Road tax band/cost’ and ‘vehicle emissions’ (including CO2), the two categories of responses relating most directly to environmental issues, have little direct influence on car choice. When asked what factors could be used to compare the environmental impact of ‘two outwardly identical cars’, the survey finds that car buyers consider ‘fuel economy’, ‘vehicle emissions’, and ‘fuel type’ as the three strongest indicators of environmental impact. Please also note that fiscal regimes for vehicles in many countries in Europe are increasingly based on the environmental performance of cars. So also consumers will become increasingly aware of the environmental (in particular CO2-performance) of vehicles. Technical parameters: Energy supply and charging indicators Most consumer studies indicate the significance of charging infrastructure and charging time for customer acceptability (ETC/ACC, 2009). Accenture (2011) in exploring different factors which could motivate the purchase of alternative vehicles, remarks that the charging possibilities and infrastructure are among the most important elements. Effective energy supply and infrastructure could restore the customer trust and, hence, support the alternative vehicle market. The battery capabilities (battery lifetime and efficiency) are additionally, potential indicators which could be critical for HEV/EV adoption. The importance of the recharging capabilities and battery performance are also highlighted in the IEA Technology Roadmap (IEA, 2011). This report

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suggests the establishment of appropriate metrics and empirical verification of the battery performance via in-use testing. Technical parameters: Battery life cycle Moreover, like the EEA (ETC/ ACC, 2009), IEA highlights the value of optimising the supply chains and ensure sufficient supply aligned with the HEV/ EV volume. IEA also proposes the engagement of standards for battery construction and disposal, highlighting the recycling option. Technical parameters: Driving range (Electric vehicles) According to Bradley & Quinn (2010),the driving range, in relation to charging possibilities and time, has a strong effect on the consumers. One of the major issues occurring with respect to driving range is the discrepancy between the desired driving range by consumers expected to fulfil their driving needs and the actual daily driving patterns and distances of consumers. In the research paper of Skippon & Garwood (2011), it is noted that EVs with range of only 100 miles (around 160 km) would gain some interest only as a potential second car and only if the range extends to 150 miles (around 240 km) then it is acceptable to be a main car. The range of the electric vehicles has been examined also in the survey from Accenture (2011). In terms of perception, only 9 percent of the respondents considered that a range of less than 200 km is acceptable, even though at the same time only 10 percent drives in a day more than 100 km (on average this value is 52 km). See also the figure below. Figure 5.2 What range would consumers want their electric vehicle to have, compared to their daily

driving distance? in Accenture (2011)

Similar results are extracted from the G4V (2011) study. According to G4V survey findings, even though on average a large majority of the respondents (81%) drives less than 100 km35 per day and only about 10 percent up to 150 km per day, the respondents indicated as a minimum range on average 308 km. The minimum requirements differ per country; Netherlands ranks on the top of the list with 389 km of minimum capacity while Sweden is the lowest with 212 km. This discrepancy

35 The results were mainly distributed from 21 to 100 km per day.

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between the countries (see figure below) reveals the difference in preferences and priorities between consumers. However, only three countries (Sweden, United Kingdom and Italy) score below the 300 km. Figure 5.3 Minimum travelling range survey results from G4V (2011)

Overall, the limitations of the driving range are a critical factor in most public policy and private studies. The IEA Roadmap (2011) defines two additional metrics, besides the battery range itself, for estimating the consumers’ needs: the daily driving distance, which will facilitate the setup of optimal range for HEVs and determine the necessary range for the EVs and, the actual-in-use vehicle efficiency and range indicating variations based on the driving style and driving conditions. Technical parameters: Other parameters Other identified parameters regarding the technical specifications of the vehicles that are relevant to consumers are, according to IEA (2011), the performance (vehicle acceleration), the safety and the reliability (average maintenance needs annually). In order for a consumer to adopt a new technology, it is important that they will not lose the amenities/ features of the previous technology. The potential loss should be compensated (e.g. the vehicle speed in EVs can be compensated by the decrease of noise and CO2 emissions). Otherwise, the previous features should be maintained intact or even amended. Additionally to that EEA in (ETC/ ACC, 2009) refers to the environmental effects and especially the emissions during the production and distribution of electricity, which depends on the source of energy production. The environmental consciousness is referred to in the Accenture survey (2011). The respondents have been positive in knowing the source of electricity but by 55 percent, they said it would not affect their decision. Financial parameters Existing literature also indicates that the financial parameters, both purchase price and operational cost are highly relevant to consumers. IEA (2011) refers to three key parameters that are interlinked: • The purchase price, which is strongly influenced by the battery costs. • The fuel cost per km. • The vehicle resale value. The cost of a battery is an important factor for both electric and hybrid vehicles. According to the EEA report (ETC/ ACC, 2009) the battery cost is considered to be one of the most important factors. IEA (2011) indicates that in order to achieve commercialisation, the battery cost should decrease. A study by Synovate in the US (Synovate, 2007) illustrates that the willingness to pay extra for an alternative vehicle is, overall, reversely related to the additional expenses, as depicted

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in the figure below. However, the survey indicates that the amount of “tolerance” has been relevantly increasing over time. Figure 5.4: Amount willing to pay for alternative vehicles over time (Source: Synovate, 2007)

The energy cost depends on the efficiency of the battery and the relative energy prices of electricity versus other fuels (IEA 2011). Operational costs of alternative vehicles are significantly lower than conventional fuel driven vehicles. The higher purchase price as a result of the battery costs can be compensated through the energy cost savings during the lifetime of the vehicles (ETC/ ACC, 2009). However, the existing surveys have demonstrated contradictory results. The McKinsey survey (2009) showed that within its parameters (mainly user-oriented) the monthly energy costs di not weight high on potential users. On the other hand, between cost and charging parameters (time, availability, costs), Accenture (2011) demonstrated that, for EVs, the charging costs were the most important attribute. Due to the fact that the surveys did not compare the same elements, it is not possible to come to a conclusion regarding the operational costs. Finally, the resale value could positively affect the consumers (either for selling or second-hand buying). One recent example is the Future Resale Value of the Azure Dynamics Transit, recently announced by CAP, to be decreased to 20 percent of the original value after three years of operation or 20,000 miles. A vehicle of £ 39,999 of capital cost would be reduced to resale value of £ 8,000 after three years and30,000 miles) User parameters The McKinsey study (2009) focused on the user-defined parameters besides the other technical and financial specifications (see figure below). In the results, the user parameters can be found within the average scores, but still in important positions, e.g. the “handles well” indicator ranks slightly higher than the purchase price. Within the other user indicators, comfort, fun and design score almost at the same level as safety. The technical characteristics, such as the size, the power etc. are found in the lower positions of the list.

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Figure 5.5: Vehicle attributes ranking by McKinsey (2009)

5.4 Stakeholders input: workshops and interviews

In addition to consumer preferences indicated in literature, the study incorporates the stakeholders’ perspective towards the information that should be provided to the consumers. This is presented from two perspectives: a) consumer requirements and b) automotive industry opinions. At first, the stakeholders’ views reflect on the consumers’ requirements by collecting opinions on (environmental) utility parameters that could be standardised in type-approval test procedures. The objective of this is to investigate what type of information consumers would wish to have (e.g. effective range, electricity consumption, impact of ancillary systems like heater air-conditioning, etc.) Secondly, the study has gathered the automotive industry’s opinions and views on potentially important technological developments (e.g. special types of hybrids) and other considerations, which should be considered when revising and complementing EV/HEV test procedures. In this context we present the industry’s thoughts about potential technologies so that we do not exclude anything inadvertently through the test regime that is proposed. In addition, where available, we present information on EV/HEV related tests procedures, e.g. related to durability or battery parameters, that industry applies on a non-regulatory basis for customer information and which could be a basis for respective harmonised test procedures at type-approval. The information in this section is based on two sources: • Two stakeholder workshops held in Brussels • Information received by specific stakeholders, partly by views or papers on this topic from

specific stakeholders, partly by interviews. The stakeholders that contributed to this study were: • ACEA • AECC (Association for Emissions Control by Catalyst)

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• ACEM • ANWB (Royal Dutch Touring Club) • CENEX • EGEA (European Federation for Transport & Environment) • European Garage Equipment Association) and FIGIEFA (Automotive Aftermarket Distributors) • FEMA • FIA (Fédération Internationale de l'Automobile)36 • Fisker Automotive • Going Electric • Honda Motors Europe • PIAGGIO • PON (one of the largest car importers in the Netherlands) • SMMT – OEM

Most of the responses focus on the industry’s perspective, a few on the consumers’ requirements. In the remainder of this section the received information will be dealt with anonymized, maintaining stakeholder confidentiality. Consumers’ requirements The following section addresses the consumer requirements that were addressed through the stakeholder consultation or interviews. Consumption, range and recharging capabilities With regard to information on consumption, range and recharging capabilities that consumers would wish to have, are suggested: • Electric / vehicle ranges in km, under standard conditions as well as the range reduction due

to winter and hot summer conditions (extreme conditions). In that way, the consumer can be better informed on what to expect and conform accordingly his expectations and driving targets.

• Energy consumption / CO2 emissions (electric and fuel). Like the ranges mentioned these can also be tested for several scenarios. Energy consumption could be differentiated for traction (average and top speed) as well as for ancillary loads, as non-traction components can represent a great volume of the energy usage

• (Battery re)charging time, as well standard and fast charging time. Suggestions for consumer-

oriented variables could be: - The recharging times, i.e. the maximum charge time from fully depleted and. - The recharging rate, i.e. how long is the wait to drive a given distance.

• Battery durability also under varying conditions. For example in extreme temperatures or with

a high auxiliary load.

• Performance like maximum speed in km/hour, acceleration and climbing capability.

• Maintenance parameters specifically related to life of major components, e.g. battery pack). Even though such information could be proven very useful to influencing consumers’ choice, it is not all yet standardised according to specified criteria. It is mentioned that potential standardisation could assist the users to shift their preference to alternative market products, such as EVs, but it

36 The input from FIA also represented ADAC automobile organisation in Germany.

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could also establish the minimum range/ threshold of the proper functioning of the aforementioned vehicles. According to a specific stakeholder, this would be applicable not only to customers who are buying new EVs but also customers who are buying used ones. This last factor is regarded as very important in order to expand to the second-hand market of electric and hybrid vehicles. Safety In addition to the already mentioned parameters, the high-voltage crash safety is brought to notice. Albeit the safety parameters are of great importance to the user, it is also noted that most safety aspects, including the safety of electric systems, are already addressed in existing standards and certification. CO2 emissions With regard to CO2 emissions attention is demanded for well-to-wheel emissions meaning CO2 emissions calculations including all stages of the energy chain from well-to-tank (WTT) and tank-to-wheels (TTW). In general attention is demanded for the EU to provide common and harmonized rules/methodology for countries to calculate WTW emissions. A specific stakeholder asks for an even broader approach and to include also the environmental impact of production and decommissioning of vehicles. Consumers may also want to know the environmental impact or CO2 emissions from production and recycling of vehicles. Costs With regard to the costs attention is demanded for: • The energy costs. This is regarded to be a key parameter in consumer information. While this

characteristic is not submitted to standardisation, it is worthwhile to refer to it as an important factor in users’ perception. Even though in most cases the actual usage cost (€ /km) is not clear for users37, indicative costs, like the costs on the US car labels in section 3.1.2., could be helpful in long-term decision making, i.e. the profit from battery usage to pure constant fuel consumption.

• The operating (like annual fuel costs) and maintenance costs. • The Total Cost of Ownership (TCO) measure including operating cost, depreciation of the

battery and the residual value of the vehicle. • Residual value of batteries of EVs as they determine to a large extent (about 1/3) of the total

value of an EV. Residual value is therefore very important to consumers and leasing companies. After 3 or 4 years, users need to know how much battery capacity is left of the original capacity. Somehow people or dealer/garage shops need to know how to measure the battery capacity at any point in time. People should also be able to make a trade-off between a purchasing a cheap battery while having a higher capacity degradation/worse durability or purchasing a more expensive battery while having lower capacity degradation/ better durability being reflected in a higher residual value.

Automotive industry technical requirements In the same way as above, the requirements from the automotive industry are addressed through the stakeholder consultation or interviews

37 The same stands also for conventional fuel users: e.g. Turrentine & Kurani (2007) mention that in US almost none of these households track gasoline costs over time or consider them explicitly in household budgets.

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Range Indicators The following parameters have been mentioned by the stakeholders for range testing, incorporating of elements of electric range measured in different conditions • Average Electric Range • Average Electric Range measured in city conditions • Equivalent All Electric Range meaning “the portion of the total charge depleting range

attributable to the use of electricity from the battery over the charge depleting range test” and • Charge Depleting Actual Range defined as “the distance travelled in a series of whole cycles

in charge depleting [CD] mode until charge sustaining [CS] mode is detected. This range must be reported to the nearest 0.1 km”. As illustrated by Figure 2.6.

It was stated by stakeholders that specifically for range extenders, PHEVs and HEVs there is no indication for fuel consumption, electric consumption or CO2 emissions. The electric consumption is also not defined for EVs. Technological developments With respect to technological developments which should be considered when updating/ complementing EV/ HEV test procedures, some stakeholders emphasize on the proliferation of electrified powertrain configurations in order to integrate: • The Extended-Range Electric Vehicles (EREV) and • The growing complexity of the electrification spectrum (from zero electrification to total

electrification) The distinction among the different types of electrified powertrains, e.g. HEVs and PHEVs are regarded to be not clearly defined for both consumers and regulators. Furthermore, new types of powertrains, such as the EREVs, are not covered from existing procedure regulations. Supplementary technologies not covered by existing driving cycles Some stakeholders also refer to additional technological developments not captured by the existing test cycles. For this the technologies with environmental benefits such as solar panels which provide additional electricity, active aerodynamics and several ITS applications (variety of intelligent systems such as regenerative braking, efficiency-improving driver feedback, adaptive cruise control, and route planning to avoid traffic) are mentioned. Charging parameters The importance of charging infrastructure options is mentioned, especially referring to the EREVs, such as Level 3 charging (high-voltage) and wireless charging. Open reparability Also the importance of the principle of “open reparability” of the EVs and HEVs is highlighted in the stakeholders’ views. More specifically, the existing Framework Directive does according to the stakeholders not contain any provisions on access to technical information, but it should be adapted in the European type-approval legislation due to the technical particularities of EVs and HEVs. For mitigation of this issue, one stakeholders proposes the following: • Repair and maintenance Information is crucial for all independent operators. • Transfer and adaptations, if necessary, of all requirements regarding repair and maintenance

information from Regulations (EC) No 715/2007 as implemented and amended by Commission Regulation (EC) No 692/2008 as amended.

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• Technical information for garage and test equipment manufacturers. • In-vehicle remote diagnostic systems to independent operators. Requirements for L-category vehicles Specifically for L-category it is mentioned that in general standardised test procedures on aspects like electric range, fuel/energy consumption and CO2 emissions could help bring about a level playing field. Besides it expected that by providing consumers with comparable and transparent data coming from standardised procedures, the confidence in the new segment of ePTWs (electric Powered Two Wheelers) may increase. Standardised tests will also allow a clear distinction between low and high quality products and will set the appropriate level for the manufacturers in the market. Until now, the regulated fields are of technical and environmental nature as defined in the Directives of 97/24/EC as amended by 2009/108/EC (see paragraph 2.2). The feeling is that the specific tell-tales38, calculation of emissions for hybrid and electric vehicles / the energy consumption (in kWh/km to CO2/km from socket to wheel in fast and normal charging modes, also to provide fairer comparison of HEVs and EVs to other technologies), the measurement of maximum power and torque, the energy from regenerating braking, the vehicles’ / electric range and the electric functional safety for battery charger and the vehicle should be regulated.

5.5 Results from consumers’ survey

In order to focus on the key issues that are relevant for this study, the consumer requirements have been validated in this study by distributing a dedicated web-based questionnaire. The main goal of the questionnaire was to show the relative importance of a list of variables extracted from the literature review and the stakeholder analysis. Research method This online survey was conducted in five countries (Belgium, France, Germany, Netherlands and the United Kingdom) among participants above 18 years of age in the possession of a (car) driving licence. Pre-selecting L- or N1-category owners proved difficult within the timeframe of this study, and in order to keep the survey manageable, the survey was conducted only for the M1 categories. In total, 527 consumers have completed the survey. The survey was conducted for the 25 parameters that were considered to be the most relevant to consumers in their purchase decision, grouped in 5 main categories (including the applied colour code): • Fuel/energy consumption and driving range (yellow) • Financial (red) • Battery and charging (green) • Performance (blue) • Car brand and car design (ochre/sand) Each parameter was scored by the respondents on a scale from 1 to 5 where 1 is the characterisation of the variable as “not important”, 2 for the option “of little importance”, 3 is for “moderately important”, 4 is for “important” and 5 is for “very important”.

38 A ‘tell-tale‘ is an optical signal which indicates that a device has been activated, is functioning correctly or not, or has failed to function at all

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Please note that as L- and N1-category owners were no part of the survey, the following results could be different for these types of owners. Please also note that the questionnaire results give a global view of consumers. Due to the relative small number of questionnaires it was not possible to present reliable results for certain sub-groups like private users of professional vehicle users. Overall results The figure below presents the overall ranking of vehicle attributes according to their relative importance. The importance of each attribute is calculated by taking the average score (on the scale from 1 to 5) for all participants. Respondents from each country sometimes demonstrated different results concerning the examined parameters (see the annex on the consumers’ survey). The three most important attributes when considering purchasing an EV or HEV are the purchase price, the availability of recharging points and safety. One of the findings that stand out is that three out of the top-five attributes are related to the battery and recharging capabilities (the green attributes in the figure below). On the other hand, the fuel and energy consumption indicators, including the range of the vehicle, are deemed to be only moderately important. Therefore, this could lead to the conclusion that the range is not paramount as long as the consumer has information on where, how and how long it takes to recharge the battery. The survey has also indicated that performance and user related preferences, except for safety aspects, score relatively low.

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Figure 5.6: Survey ranking (average for all countries); see previous page for colour explanation. Ranking scale; no absolute scale.

Technical indicators: Battery and recharging indicators Battery and recharging indicators have not yet been submitted in a regulatory framework, opposite to the other variables. At the same time, relating to consumer opinions on technical indicators, these are the highly important in their decision process. Variables such as availability of recharging points, lifetime of the battery and recharging capabilities scored within the top five positions. In addition, the other two variables of this cluster, namely battery recharging options, ranked among the first ten indicators. In fact, the availability of charging points scores 4.35 out of 5, the battery lifetime 4.30 and the recharging capabilities 4.27. Not all defined parameters of the survey are considered to be relevant for revised testing procedures., e.g. the availability of charging points or the recharging capabilities. However, they indicate the importance of battery charging as a whole and can be taken into further consideration for prospective use in the policy schemes for the promotion of such vehicles (e.g. in labelling).

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Technical indicators: Performance indicators The performance indicators include all the technical parameters of a M-category vehicle which do not submit to the other technical fields (energy consumption and battery characteristics). As it is shown in the survey results, these indicators, besides safety, score moderately compared to the other clusters39. Comfort and capacity are ranked in the 13th and 14th position, while the CO2 emissions rank on the 15th position. Hence the survey indicates that these characteristics are, regarding the consumers’ preferences not so crucial. The end-users can choose from a vast variety of vehicles with different comfort and capacity characteristics so it seems that there is little attention drawn to that matter. Moreover, the elements of maximum speed and acceleration can be found at the bottom of the stack. That can be partially explained from the assumption that HEVs and EVs are considered to be mainly city vehicles. Within the city boundaries the maximum speed and acceleration prospects are limited. Therefore, it is possible that the consumers do not consider these indicators so important. However for the options of noise and CO2 emissions, it is possible that they rank moderately due to the consumers’ unawareness of their effects. Within the benefits of owning for example an EV, are, the reduction of the noise (in- and outside the vehicle) and the potential of zero-emission at the source of use, both decreasing significantly the negative external effects of driving, especially in urban areas. Overall, the users of the survey seem more concerned about the battery choices and the energy consumption, than the actual performance of their vehicles. Even though we cannot clearly conclude to that, their motivation seems to be driven mainly from the technical aspects of the vehicle itself (e.g. reduction of consumption, fuel efficiency etc.) and to a less extent on the environmental and societal benefits. Technical indicators: Fuel and electric energy consumption indicators These indicators are divided into the energy consumption and the range indicators. In general there are testing procedures for both categories. Nevertheless, these are limited to the standard conditions. In this case, the survey explores what is the consumers’ opinion towards not only the consumption and range on average but also for several identified conditions. In general, the energy consumption indicators are ranked higher by the consumers than the ones regarding the driving range. The survey indicates that energy efficiency seems to be more important for the end-users than the actual range of driving under different conditions. On the other hand, the low score of the driving range indicators could occur probably because the target market is not interested solely in EVs. People may think “As long as I am concerned about the electric range at all, I won’t buy an EV” and consequently do not bother assigning a high importance to this parameter. Other may think “I am only interested in PHEVs and range extender so I am not worried about the range”. Additionally to that, the interest of the end-users is shifted from the driving range to the battery features. Hence the uncertainty caused by the limited driving range can be compensated through the guarantee of availability of recharging points, recharging capabilities and recharging times. The consumers seem less interested in the different options of both energy consumption and driving range. Even though this is considered to be, for the stakeholders, really valuable information, it is possible that the average user is not familiar with such specialised data. Furthermore, the average user for these countries drives HEVs/ EVs in mainly urban roads; hence he does not come, in general, across extreme weather/ road conditions.

39 The performance characteristics score still quite high with most of them having an average more than 3.7 (moderately important to important). Only the acceleration and speed indicators score lower than that with 3.24 and 3.30 respectively).

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Financial indicators Even though financial indicators are outside of the study scope, the survey does confirm that financial indicators play a highly important role in consumer decision making. As expected, the purchase price is ranked number one (score 4.45 out of maximum 5). The fuel/energy price ranks among the first ten indicators and is the second most important financial variable. Taxes are of moderate importance to consumers. Finally, resale and depreciation value score the lowest (on the 19th position with average value of 3.71). User related indicators The two indicators under this cluster, namely the car brand (brand loyalty and preferences) and design, do not gain high interest compared to the other indicators, according to this survey, of the end-users. It seems as the vehicle owners when it comes to purchasing an alternative vehicle are not focusing their attention in the design and the brand options as much as they do in the other indicators.

5.6 Summary

In the previous chapters the existing legislation was reviewed to identify tests to be performed and the parameters to be measured with regard to the type approval of EVs and HEVs respectively. In addition this chapter made an overview of the key views and considerations from a consumers’ and an industry’s perspective, based on three applied approaches; a literature review, a stakeholder consultation and a consumers’ survey. The chapter not only shows a wide range of technical parameters that can be related to (standardised) testing procedures and type-approval but also a number of financial and user parameters announced by the stakeholders. With regard to the technical parameters four main parameters result from the stakeholder analysis, combining the results of the three research approaches:

1. The (driving) range / performance under different conditions: a. Range under normal conditions b. Range under winter and summer conditions (‘extreme temperatures) c. Range with a high ancillary load d. Range in city conditions

2. Battery capabilities:

a. Durability / Battery lifetime under normal conditions b. Durability / Battery lifetime under ‘extreme’ conditions c. Efficiency / Driving range of ageing battery

3. CO2-emissions / energy consumption:

a. Tank-to-wheel versus well-to-wheel b. Emissions under different scenarios

4. Charging time of battery:

a. Standard charging time b. Fast charging time

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The overview shows that from the stakeholders in particular information is requested about the ‘technical performance’ (= range, battery efficiency and emissions) of EV and HEV vehicles under different scenarios. The stakeholders want good information about the performance of these vehicles in different weather conditions, in different types of trips and at a different age of the battery. Although outside the scope of type-approval the chapter also shows that besides technical parameters also financial and user parameters of EVs and HEVs are very important for stakeholders. On aspects like the purchase and the fuel price, the fiscal regime, the resale value, costs per km, recharging facilities and safety good information is requested.

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6 Summary, discussion and conclusions

Introduction The purpose of this scoping study, instigated by the European Commission, was to support and help inform any future revisions of specific type approval test procedures related to emissions and the environmental utility of Electric Vehicles (EVs) and Hybrid Electric Vehicles (HEVs). The objective of the project was to identify tests to be performed and the parameters to be measured with regard to the type approval of light duty electric and hybrid vehicles (EVs and HEVs respectively). Specifically this includes reference to: • Pollutant emissions; • Electricity and fuel consumption / CO2 emissions; • Electric range; • Battery charging time in different atmospheric conditions; • Durability of batteries (charging cycles). The structure of this project was based on three elements: • A review of the existing and proposed type-approval legislation on vehicle emissions. It covered

light passenger and commercial vehicles, powered two- or three-wheel vehicles and quadricycles. Recent UNECE developments regarding heavy duty hybrid vehicles were also reviewed.

• A review of stakeholder requirements on type-approval parameters. This step comprised a stakeholder consultation in the automotive industry, users and other relevant interest groups.

• A summary, discussion and conclusions based on the previous two elements. This chapter addresses the third element, but starts by briefly summarising the first two, which have been described in much more detail in the preceding chapters. The main findings are then discussed, alongside their potential implications for the future development and enhancement of type approval requirements. This discussion section addresses the specific areas of interest listed above (pollutant emissions, electricity and fuel consumption, electric range, etc.). Finally, a set of broad conclusions are drawn from the work carried out for this study.

6.1 Summary of type-approval legislation and developments

Review of existing legislation: light passenger and commercial vehicles In the case of the hybrids / electric vehicles, current standardised test procedures are still mostly based on procedures for the conventionally fuelled cars that have dominated the market for many decades. These do not always fully address the particular characteristics and risks of (P)HEVs and EVs. The European type-approval regulations for M1 and N1 vehicles are covered by Regulations (EC) 715/2007 and 692/2008 (the latter being the implementing regulation). These specify the tests to be performed together with the limits to be met. There are six main tests to control the emissions: Type 1 test: Verifying the average exhaust emissions at ambient conditions; Type 2 test: Measuring carbon monoxide at idling speeds; Type 3 test: Verifying emissions of crankcase gases;

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Type 4 test: Determination of evaporative emissions; Type 5 test: Verifying the durability of pollution control devices; Type 6 test: Verifying the average emissions at low average temperatures. Regulation (EC) No. 692/2008 also specifies a test for the measurement of carbon dioxide emissions and fuel/energy consumption and a test for electric range. There is some commonality between European and UN Regulations – specifically UN Regulations 83 and 101 – though with certain exceptions. For the Type 1 emissions test, and the test for measuring the CO2 emissions and fuel/energy consumption, the vehicle is driven over a set test cycle while the emission and fuel/energy consumption is determined. Currently the NEDC (New European Driving Cycle) is used. However, work is currently progressing on developing a World harmonised test cycle (WLTC) and test procedure (WLTP). This should provide results more representative of real-world driving than the current test. Review of existing legislation: two- or three-wheeled motor vehicles Mopeds, motorcycles, tricycles and quadricycles are classified as L-category vehicles according to Directive 2002/24/EC and UN R.E.3. Currently, Directive 97/24/EC and its subsequent amendments specify the emissions related type approval regulations in Europe. However, these regulations are currently in the process of being repealed and replaced with a new “split level approach” regulatory package which includes: • A Co-decision act:

- Regulation (EU) 168/2013 • Delegated acts:

- REPPR – Regulation on environmental and propulsion performance requirements - RVCR – regulation on vehicle construction and general requirements - RVFSR – regulation on vehicle functional safety requirements

• Implementing act: - RAR – regulation on administrative provisions

As per light-duty vehicles, various tests are (or are proposed to be) used to control the emissions from L-category vehicles. These also include tests to measure CO2 emissions and fuel/energy consumption. As part of the World Harmonisation process, a realistic test cycle for L-category vehicle has been developed – the WMTC cycle. This has already been incorporated within UN Global Technical Regulation (GTR) No 2 and the first version of the test is used as an alternative for motorcycle type 1 testing. In the current draft of the relevant delegated act, it is proposed that the cycle from GTR No. 2 as amended will be used in future EU type-approval test procedures. Generally speaking, the proposals follow the same basic test procedures and measured parameters as are already in place for M1 and N1 vehicles. Review of technologies and recent regulatory developments pertaining to heavy duty passenger and commercial vehicles A wide range of electric, hybrid-electric and non-electric hybrids are available or being developed for heavy duty vehicles (trucks and buses). The applicability of particular technologies is highly dependent on the vehicle’s likely duty cycle.

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An Informal Group on Heavy Duty Hybrids (HDH) was established by GRPE as part of the UNECE regulatory development process in 2010. This Informal Group’s work is on-going, with completion expected early in 2014. The Group has commissioned new research and reviewed existing (Japanese) legislation and international (SAE) standards. It is currently working towards drafting an amendment to Global Technical Regulation No. 4 for adoption by GRPE and WP.29 in 2014. The first draft of that amendment was published in May 2013, introducing a new Annex 8 and allowing for both a Hardware-in-the-Loop Simulation (HILS) procedure (based on existing Japanese legislation but modified in the light of the research findings) and, as an alternative, a powertrain procedure (based on the US-EPA procedure).

6.2 Review of stakeholder requirements

In addition to a review of the existing legislation an overview was made of the key views and considerations from a consumers’ and an industry’s perspective, based on three applied approaches; a literature review, a stakeholder consultation and a consumers’ survey. With regard to the technical parameters, four main parameters result from the stakeholder analysis, combining the results of the three research approaches: 1. The (driving) range / performance under different conditions:

a. Range under normal conditions b. Range under winter and summer conditions (‘extreme temperatures)) c. Range with a high ancillary load d. Range in city conditions

2. Battery capabilities:

a. Durability / Battery lifetime under normal conditions b. Durability / Battery lifetime under ‘extreme’ conditions c. Efficiency / Driving range of ageing battery

3. CO2-emissions / energy consumption:

a. Tank-to-wheel versus well-to-wheel b. Emissions under different scenarios

4. Charging time of battery:

a. Standard charging time b. Fast charging time

The overview shows that from the stakeholders in particular information is requested about the ‘technical performance’ (= range, battery efficiency and emissions) of EV and HEV vehicles under different scenarios. The stakeholders want good information about the performance of these vehicles in different weather conditions, in different types of trips and at a different age of the battery.

6.3 Discussion

This section pulls together the findings from both the legislative reviews and the stakeholder requirements work, to assess the extent to which current type approval arrangements, or those

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already under development, are likely to generate information perceived to be of use and value to consumers and other stakeholders. The focus is on addressing the fundamental objective of this study, which was to identify the tests to be performed and the parameters to be measured with regard to the type approval of light duty electric and hybrid vehicles (EVs and HEVs respectively). Specifically this includes reference to: • Pollutant emissions; • Electricity and fuel consumption / CO2 emissions; • Electric range; • Battery charging time in different atmospheric conditions; • Durability of batteries (charging cycles). Each of these specific issues is discussed in turn. Pollutant emissions While this topic did not feature in the parameters likely to be of importance to consumers, it is naturally a subject of considerable interest to many, not least regulatory authorities, health professionals and city governments. It has long been a key focus for type-approval requirements, and this focus looks set to continue. A major reason for the appeal of EVs and HEVs to such groups is their potential to reduce pollutant emissions, particularly in cities, through either eliminating hydrocarbon-fuel combustion altogether (in the case of EVs) or greatly reducing the need for light duty vehicles to operate in “combustion mode”, particularly for (often short) urban journeys (in the case of HEVs). For cars and vans (M1 and N1), considerable regulatory progress has already been made over recent years, with Euro 5 requirements already in place and Euro 6 taking effect from 1 September 2014. As well as moves to introduce more representative drive cycles, discussions are also taking place within UNECE for further enhancements, e.g. to cover particulate mass and number, and to cover a wider range of pollutants. For L-category vehicles, existing requirements are some way behind (at Euro 2/3), but a legislative roadmap is being introduced to move in a series of planned steps to full Euro 5 compliance by 2020-21. It thus appears, from the evidence gathered for this study, that the tests and parameters needed to address the topic of pollutant emissions are already well covered by existing type approval arrangements, or will be by legislation already at an advanced stage of implementation. Electricity and fuel consumption / CO2 emissions Despite overwhelming and compelling scientific evidence showing the links between fossil-fuel combustion, CO2 emissions, global climate change and its likely severe and adverse economic and societal impacts, the evidence gathered for this study suggests that the public at large are still largely uninterested in the environmental impacts of vehicles, including CO2. Presumably for personal economic reasons, consumers seem to be somewhat more interested in a vehicle’s energy consumption (fuel and/or electricity), and this interest extends to the performance under a wide variety of conditions (e.g. weather, gradients, journey type). For the minority of consumers who are concerned about CO2 emissions, it seems, understandably, that they would prefer test parameters/information pertaining to the big picture, i.e. well-to-wheel or even full lifecycle analysis data, rather than just direct emissions at the tailpipe. These consumers seem to understand that EVs and HEVs can only be “zero emission” vehicles in use if the electricity they consume is produced by wholly renewable/sustainable/zero-carbon methods, and can only be truly “environmentally friendly” if emissions in their production and ultimate disposal/recycling are also minimised.

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These issues have clear potential implications for future type approval arrangements. Existing legislation, and that under development or discussion, focuses purely on tailpipe emissions. A variety of approaches to allocating upstream fuel/energy production emissions already exist, as do life cycle analysis methodologies. Integrating these approaches into type approval legislation in a fair, realistic and straightforward way will, this study suggests, be key future challenges. On the topic of in-use fuel/electricity consumption, recent and on-going legislative developments have taken some important steps. For M1 and N1 vehicles, test provisions now exist to measure fuel/energy consumption for all forms of EVs and HEVs. Further planned refinements to the driving cycle will likely make these parameters more representative of (some) real-world conditions. Discussions are also underway within UNECE aimed at addressing the issue of fuel/energy consumption in a range of different conditions, e.g. under conditions of very hot or cold weather (with the air-conditioning or cabin heater in operation) or driving in hilly terrain. For L-Category vehicles, the proposals forming part of the development of the delegated acts include provisions for fuel/energy consumption measurement and CO2 emissions (in use). Given the more limited range of conditions under which such vehicles tend to be used (as compared to cars and vans), and the obvious lack of ancillary loads like heaters or air-conditioning systems for many such vehicles without an enclosed driver/rider cabin, there is less pressure to consider the effects of widely varying weather conditions. Electric range Range is closely related, of course, to the fuel/energy consumption characteristics of a vehicle, and seems from the stakeholder evidence gathered to be an important subject in the minds of consumers and other stakeholders. The experience of EV users tends to be that initial range “anxieties” diminish rapidly as they gain confidence that they can go about their everyday journeys (which are typically of much lower distances than the range) on a single charge. The availability of recharging infrastructure also helps to alleviate concerns about running out of battery power. For pure EVs, the reporting of “range” is quite straightforward for consumers to understand, at least under standardised driving conditions without the use of heaters or air-conditioning. Provisions exist or are in the process of being implemented for this type of measurement of “range”. HEVs, however, present a much more complex situation. To some extent, the concept of “range” for such vehicles is less significant, because they can be re-fuelled quickly and easily just like conventional ICE vehicles. Measuring and reporting a range, though, is complicated by how the battery and fuel systems work together, as well as by the effects of weather, gradient, ancillary systems, etc, (which are also relevant to EVs). UNECE developments are attempting to address these issues by defining various different types of “range”. The stakeholder review evidence suggests that consumers, however, value simplicity and metrics that relate to their anticipated usage patterns, so another key challenge for future type-approval testing and reporting is to develop range-related metrics that consumers can readily understand and use. This might, for example, involve defining a small set of standard (but representative) journeys, and reporting how much electricity and/or fuel is likely to be consumed in order to complete those journeys (under typical winter/summer weather conditions). Example journey types might be a short shopping journey (of, say, 4 km under urban conditions with a one hour stop and then a return 4 km journey), a typical commute (of, say, 30 km on a mix of urban and highway roads, including hills, with an 8 hour stop and then a 30 km return trip), and a long-distance journey (of, perhaps, 200 km or more, mainly on motorways).

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Battery charging time in different atmospheric conditions Owners/users of EVs and (P)HEVs will, the stakeholder review suggests, be interested in how long it takes to charge the battery, both under “standard” charging conditions (akin to overnight charging at home) and “fast” charging (e.g. when they need a rapid energy boost to continue or complete their journey). They particularly want to know how these vary with weather conditions and as the battery itself gets older. These battery and charging-system performance issues are not currently addressed by type approval legislative tests, nor by planned future developments. Work underway in UNECE aims to address some of them, e.g. the effects of different charger efficiencies on charge time, but, generally speaking, they look set to remain largely un-regulated. Another key challenge, therefore, is to identify means by which charge time, and how it varies, can be tested and reported. It is likely that the basic elements for such testing are already in place, or will be introduced, for M1 and N1 category vehicles, e.g. testing at extreme temperatures and durability testing. Incorporating some measures of charge time and/or how that time varies as temperature changes or the vehicle mileage increases could thus be fairly straightforward. The testing methods currently being implemented for L-category vehicles, however, will not cover the required parameters to assess performance in extreme (hot and/or cold) atmospheric conditions. If usage of these vehicles changes in the future and consumers indicate a need for such information, testing in line with that for M1 and N1 category vehicles may also be needed. Durability of batteries (charging cycles) The stakeholder review highlighted “lifetime of the battery” as a very important issue. The relatively high initial costs of battery-powered vehicles would be further exacerbated if the battery needed to be replaced too often. Range depletion (reduced range as the battery deteriorates) and efficiency loss (more KWh needed to drive the same journey as the battery deteriorates) are also related areas (parameters) of concern. As with the battery charging time issue above, existing and planned type-approval requirements do not address battery durability issues. However, and again as with charge time, the basic building blocks for such testing probably exist or are already under development. Durability testing, for example, could quite readily incorporate assessments of range depletion and efficiency loss (though would need to be extended to pure EVs as well as HEVs), and those could be combined to indicate a likely battery lifetime (i.e. the mileage and/or number of charge cycles after which the battery performance is likely to have deteriorated to unacceptably low levels). A final key challenge, however, may well be to ensure that simulated/accelerated durability testing is realistically correlated to real-world usage conditions for batteries (in a similar way to that already implemented for pollution control devices).

6.4 Conclusions

• In the case of the hybrids / electric vehicles, current standardised test procedures are still mostly based on procedures for the conventionally fuelled vehicles. These do not always fully address the particular characteristics and risks of (P)HEVs and EVs.

• Various types of information are regulated through type-approval legislation, but many new types of information with respect to HEVs and EVs are to date not regulated. In particular the battery performance of (P)HEVs and EVs is not tested under many different conditions.

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• This means that this information is not always provided to consumers or that manufacturers

may use different test procedures and apply different test/laboratory conditions, resulting in different estimates and potentially confusing consumers.

• Stakeholders, in general are keen for more information to be made available, and for it to be standardised. There is a genuine desire and requirement to be able to compare like-with-like parameters, rather than have different non-standardised measures or no information at all.

• As light duty electric and hybrid vehicles become more commonplace and their technologies mature, international harmonisation of the tests to be performed and the parameters to be measured with regard to their type approval will develop; and the feedback from the stakeholder review undertaken as part of this programme will continue to have relevance. A good example of where the stakeholders believe there is potential to improve future regulation is the performance of the battery (the range/ performance of the vehicle) under a wider range of operating conditions.

• The study has identified several key likely future challenges in further developing and enhancing type-approval tests and measurement parameters for light duty EVs and HEVs. These can be summarised as: - Integrating upstream fuel/energy production emissions and life cycle analysis methodologies

into type approval legislation in a fair, realistic and straightforward way. - Developing range-related metrics that consumers can readily understand and use. - Identifying means by which charge time, and how it varies, can be tested and reported. - Ensuring that simulated/accelerated durability testing is realistically correlated to real-world

usage conditions for batteries.

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Glossary

Term Definition

%SoC Percentage state of charge

ACEA European Automobile Manufacturers' Association

ACEM Association des Constructeurs Européens de Motocycles / The motorcycle

Industry in Europe

ADB Asian Development Bank

AECC Association for Emissions Control by Catalyst

AER Average Electric Range

AER city Average Electric Range measured in city conditions

ANWB Royal Dutch Touring Club

AVG Average driving conditions (combination of urban and non-urban)

BEV Battery electric vehicle

BEV Battery electric vehicle, see EV and FCEV

biomethane Methane sourced from renewable sources, rather than drilling

C/U City / Urban driving conditions

CARB California air resource board

CD Charge depleting mode. This is when energy is able to be drawn from the

battery, and its state of charge decreases

CENEX “the UK's first Centre of Excellence for low carbon and fuel cell technologies”

CNG Compressed Natural Gas

CO Carbon monoxide

CO2 Carbon dioxide

CS

Charge sustaining mode. This is when the battery in a HEV has reached a state

of charge when the vehicle begins to supply energy to the battery from the

conventional engine, to prevent it becoming fully discharged

DID Direct Injection Diesel

Dynamometer Is a machine used to measure mechanical power. For vehicle testing is may be

used to provide inertial resistance.

EAER

Equivalent All Electric Range: meaning “the portion of the total charge depleting

range attributable to the use of electricity from the battery over the charge

depleting range test”

eBike Electric moped or motorcycle

EC European Commission

ECE R15 cycle Urban Driving Cycle

EEA European environment agency

EGEA Environment European Garage Equipment Association

EPA Environmental Protection Agency: An agency in the USA

ePTW Electric powered two wheelers

EREV Extended-Range Electric Vehicles

ETC/ACC European Topic Centre on Air and Climate Change

ETW electric two-wheelers, see eBike and Pedalecs

EU European Union

EUC Elementary Urban Cycle – Parts of an L-category emissions driving test cycle

EUD Extra-Urban Driving cycle – Parts of an L-category emissions driving test cycle

EUDC Extra Urban Driving Cycle – Parts of an M/N-category emissions driving test

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Term Definition

cycle

EV electric vehicle

FC Fuel Cell

FCEV Fuel Cell Electric Vehicle

FCM Fast charging mode

FCV Fuel Cell Vehicle

FCV Fuel cell vehicle

FEMA The Federation of European Motorcyclists' Associations

FIA Fédération Internationale de l'Automobile

FIGIEFA Automotive Aftermarket Distributors

GTR Global Technical Regulation

H/nU Highway / non-urban driving conditions

H2 Hydrogen

H2O Water

HEV Hybrid Electric Vehicle

HV Hybrid vehicles

ICE Internal combustion engine ICEVs Internal combustion engine vehicles

IEA International Energy Agency

IWG Informal working group. A group under the UN ECE

kg Kilogramme

km Kilometre

Km/h Kilometre per hour

L Light vehicles

Light

A 2 or 3 wheeled vehicle.

And 4 wheeled vehicles under 450kg (or 600kg for goods vehicles) and a

propulsive performance of ≤90 km/h or ≤15 kW.

LowCVP Low carbon vehicle partnership

m Million

M1 and N1 Categories for Light Duty passenger and Light Duty goods vehicles

MIL Malfunction indicator light

MPG Miles per gallon, a measure of fuel consumption. Note: this value is different

under the USA and Imperial systems

MPGe Miles per gallon equivalent

NEDC New European Driving Cycle

NHTSA National Highway Traffic Safety Administration: An agency in the USA

NMHC Non-methane hydrocarbons NOVC Not on-board vehicle charging, i.e. not a plug-in hybrid

NOx Oxides of nitrogen

OBD On-board diagnostic

OCE Off cycle emissions, emissions which occur outside of a predefined test cycle

OICA Organisation Internationale des Constructeurs d’Automobiles: The International

Organization of Motor Vehicle Manufacturers

Opacimeter Apparatus for detecting particulates in exhaust gases by shining light through a

sample

OVC Off vehicle charging, see PHEV

Pedalecs Power assisted bicycles

PEV Pure electric vehicle, see EV

PHEV Plug-in Hybrid Electric Vehicle

106


Term Definition

PM Particulate matter

PN Particulate number

PON one of the largest car importers in the Netherlands

PTI Periodic technical inspection

RAR European Regulation on administrative provisions, currently in draft

RCB Residue charge balance

Rcda

Charge Depleting Actual Range: defined as “the distance travelled in a series of

whole cycles in charge depleting mode until charge sustaining mode is detected.

This range must be reported to the nearest 0.1 km”

REESS Rechargeable electric energy storage system: a system storing electric energy

REPPR European Regulation on environmental and propulsion performance

requirements, currently in draft

RVCR European Regulation on vehicle construction and general requirements, currently

in draft

RVFSR European Regulation on vehicle functional safety requirements, currently in draft

SILS software-in-the-loop-simulation

SM Standard mode

SMMT Society of motor manufacturers and traders

SOC state of charge

SR Severe road gradient conditions

SRC Standard Road Cycle: a durability distance accumulation test cycle for M1 and N1

category vehicles. Detailed in UN Regulation 83, originally developed in the USA

SRC-LeCV

Standard Road Cycle for Light category vehicles: a durability distance

accumulation test cycle taking the SRC as a base and modified for the

capabilities of four classes of L-category vehicles

StW Standard weather and road gradient conditions (no use of air conditioning and

flat roads)

Super cycle A set of driving instructions used in a test cycle which are repeated a number of

times.

SW Severe weather conditions

TCO total cost of ownership

THC Total hydrocarbons

TTW Tank to wheel

UDC Urban Driving Cycle – Parts of an M/N-category emissions driving test cycle

UN United Nations

UNECE or UN ECE United Nations Economic commission for Europe

VCA Vehicle Certification Agency: The designated UK Vehicle Type Approval

authority

Volatility This is a measure of a substances tendency to vaporise

VOSA Vehicle and Operator Services Agency: The UK authority in charge of PTI and on

road conformity

Wh Watt hours

WHTC World harmonised test cycle, for heavy duty engines

WHVC World harmonised vehicle cycle, for heavy duty vehicles

WLTC World harmonised light-duty test cycle

WLTP World harmonised light-duty test procedure

WMTC World harmonised motorcycle test cycle

WoT Wide open throttle, i.e. full throttle

WTT Well-to-tank

107


Term Definition

WTW Well-to-wheel

108


Overview L-category vehicles Annex A

109


Application of test requirements for Annex Btype-approval and extensions in Regulation (EC) No. 692/2008 for M1 and N1 vehicles

Table 1: Summary table of test requirements for type-approval

Vehicle

category

Vehicles with positive ignition engines including hybrids Vehicles with

compression

ignition

engines

including

hybrids

Mono fuel Bi fuel Flexi

fuel

Flex

fuel

Mon

o

fuel

Reference

fuel

Petrol

(E5)

LP

G

NG/Biometh

ane

Hydrog

en

Petrol

(E5)

Petrol (E5) Petrol

(E5)

Petrol Diesel

(B5)

Dies

el

(B5) LPG NG/Biometh

ane

Hydrog

en

Ethano

l (E85)

Biodies

el

Gaseous

pollutants

(Type 1

test)

Yes Ye

s

Yes Yes

(both

fuels)

Yes (both

fuels)

Yes

(both

fuels)

Yes

Particulate

s (Type 1

test)

Yes

(direct

injectio

n)

-

- Yes

(direct

injectio

n)

petrol)

Yes (direct

injection)

(petrol)

Yes

(direct

injectio

n)

(both

fuels)

Yes

Idle

emissions

(Type 2

test)

Yes Ye

s

Yes Yes

(both

fuels)

Yes (both

fuels)

Yes

(both

fuels)

-

Crankcas

e

emissions

(Type 3

test)

Yes Ye

s

Yes Yes

(petrol)

Yes (petrol) Yes

(petrol)

-

Evaporativ

e

emissions

(Type 4

test)

Yes - - Yes

(petrol)

Yes (petrol) Yes

(petrol)

-

Durability

test (Type

5 test)

Yes Ye

s

Yes Yes

(petrol)

Yes (petrol) Yes

(petrol)

Yes

Low

temperatu

Yes - - Yes

(petrol)

Yes (petrol) Yes

(both

111


Vehicle

category

Vehicles with positive ignition engines including hybrids Vehicles with

compression

ignition

engines

including

hybrids

Mono fuel Bi fuel Flexi

fuel

Flex

fuel

Mon

o

fuel

re

emissions

(Type 6

test)

fuels)

In-service

conformity

Yes Ye

s

Yes Yes

(both

fuels)

Yes (both

fuels)

Yes

(both

fuels)

Yes

On-board

diagnostic

s

Yes Ye

s

Yes Yes Yes Yes Yes

CO2

emissions

and fuel

consumpti

on

Yes Ye

s

Yes Yes

(both

fuels)

Yes (both

fuels)

Yes

(both

fuels)

Yes

Smoke

opacity

- - - - - - Yes

112


Application of test requirements for Annex Ctype-approval and extensions in Regulation (EC) No. 168/2013 for L category vehicles

113


Summary table of current legislative Annex Dtests and measurement parameters

Table1: Abbreviations used in this annex

Key Abbreviation

Carbon dioxide CO2

Carbon monoxide CO

Nitrogen Oxides NOx

Non-methane hydrocarbons NMHC

Particulate matter PM

Total hydrocarbons THC

Table 2 Light passenger and commercial vehicles Regulations

Regulation Test Approach Parameters Remarks

EC No.

692/2008

and UN R83

Type 1: Exhaust

emissions at

ambient

conditions

Chassis dynamometer:

Part One (4 urban

cycles) + Part Two (1

extra urban cycle)

Detailed provisions for

hybrid electric vehicles:

OVC vehicles tested in

two conditions (Condition

A – fully charged and

Condition B – minimum

charge)

SOC calculation and

balance for NOVC

vehicles

Regulated

performance

limits (Euro 5 or

6):

CO (g/km)

THC (g/km)

NMHC (g/km)

NOx (g/km)

PM (g/km)

Also

determined:

Battery State of

Charge

Electric range

(km)

Main control of toxic

pollutants linked to air

quality

These metrics are not

generally used by

stakeholders in marketing

or by consumers (data is

published in UK by VCA)

Range tests can be very

long and there are two

procedures possible

Type 2: CO at

idling speeds

Two speeds: normal idle

and high idle

Hybrid electric vehicles

must be provided with a

“service mode” to ensure

fuel consuming engine

running

CO

(concentration

of exhaust

gases - %)

Type 3:

Crankcase gas

emissions

Crankcase pressure in

three conditions of

engine operation

Hybrid electric vehicles

must be provided with a

“service mode” to ensure

fuel consuming engine

running

Crankcase

pressure

Type 4:

Evaporative

emissions


preparation (urban and

extra urban cycles) + hot

soak + diurnal loss

THC (g/test) UN Regulation 100

requires aqueous batteries

(such as lead) to have a

hydrogen evaporation test,

114


Regulation Test Approach Parameters Remarks

Provisions for hybrid

electric vehicles:

preconditioning for OVC

and NOVC vehicles

which requires charging the

vehicle at different levels

whilst measuring the

ambient air in a sealed

chamber

Type 5:

Durability of

pollution control

devices

Deterioration factors

applied to emissions to

establish compliance with

emission limits during

vehicle life

Minor provisions for

hybrid electric vehicles

CO (g/km)

THC (g/km)

NMHC (g/km)

NOx (g/km)

PM (g/km)

(Euro 5 or 6)

Type 6: Average

emissions at low

ambient

temperatures


preconditioning (Type 1

test) + low ambient

temperature soak +

emission measurement

(Type 1, Part One test)



CO (g/km)

THC (g/km)

Also

determined:

CO2 (g/km)

On-board

diagnostics test

Failure simulation of

relevant systems +

preconditioning (Type 1

test) + ODB system test

(Type 1 test)



CO (g/km)

NMHC (g/km)

NOx (g/km)

PM (g/km)

EC No.

692/2008

and UN

R101

CO2 emissions

and fuel

consumption

Chassis dynamometer

testing, generally using

Type 1 test cycles

Separate procedures

according to powertrain

type: ICE, purely electric,

HEV or PHEV

CO2 (g/km)

Fuel

consumption

(l/100km)

Electric energy

consumption

(Wh/km)

Electric range

(km)

(no limits –

results to match

declared values)

CO2 is a greenhouse gas

contributing to climate

change

No limits are applied, but

metrics and results are

used by stakeholders in

marketing and are

available to consumers to

inform choices

Several procedures each

relevant to a different

hybrid strategy

The different procedures

mean that results are no

longer directly comparable

as have assumptions on

range, and that electric

energy is 0g/km CO2

Range tests can be very

long and there are two

procedures possible

115


Table 3: Powered two-, three-wheelers and quadricycle Regulations

Regulation Type and

power band

Test Approach Parameters Remarks

Directive

97/24/EC with

reference to

driving cycles

in:

UN/ Regulation

47

UN/ Regulation

40

UN/ Global

Technical

Regulation No.

2

Mopeds:

Two-wheeled

mopeds(L1);

three wheeled

mopeds (L2);

light

quadricycles

(L6)

Type 1:

Checking the

average

emissions of

gaseous

pollutants in a

congested

urban area.

Chassis

dynamometer;1

urban cycles

repeated 8

times; warm

start (4 parts to

warm, 4 parts

to measure

emissions); no

provisions for

hybrid electric

vehicles

CO; Combined

HC and NOx;

In g/km

(Euro 2)

Higher CO limit

for three-wheel

mopeds and

light

quadricycles

Type 2:

measuring

emissions of

CO and HC at

idling speed

Performed

immediately

following test 1;

no specification

for idle engine

speed

CO; HC

in % of volume

of total

emissions

(Euro # is n/a)

No limits

Recorded for

information only

Motorcycles (L3

& L4) only

Manufacturers

can choose to

run the driving

cycle detailed in

UN GTR No 2

(Also known as

WMTC) as an

alternative to

the UN/ R40

cycle

If vehicle

capable of

< 130 km/h

Type 1:

Exhaust

emissions at

ambient

conditions

WMTC cycle

Part 1 & 2

Chassis

dynamometer;

The WMTC

cycle has 3

parts but 2 only

configurations,

the R40 has 2

parts but 3

configurations;

both cold start;

OVC vehicles

tested in two

conditions

(Condition A –

fully charged

and Condition B

– minimum

charge)

CO; HC; NOx

(Euro 3)

In g/km

Emission limits

have been

calculated to be

comparable to

ECE R40 test

Part 1 of the

driving cycle is

designed for

mopeds,

however it is

not part of the

legislation at

this stage

If vehicle

capable of

≥ 130 km/h

Type 1:

Exhaust

emissions at

ambient

conditions

WMTC cycle

Part 1, 2 & 3

Motorcycles (L3

& L4) only

UN/ R40

If

vehicle’sswept

volume < 150

cc

Type 1:

Exhaust

emissions at

ambient

conditions

CO; HC; NOx

(Euro 3)

In g/km

Different values

for with and

with EUD part

However, there

is no change in

limits between

116


Regulation Type and power band


UDC cold

the capped

(max speed 90

km/h) and

uncapped (max

speed 120

km/h) EUD part

If vehicle’s

swept volume

≥ 150 cc

And capable of

≥ 110 km/h

Type 1:

Exhaust

emissions at

ambient

conditions

UDC + EUD

cold

If vehicle’s

swept volume

≥ 150 cc

And capable of

< 110 km/h

Type 1:

Exhaust

emissions at

ambient

conditions.

UDC + EUD

cold

With speed

capped at 90

km/h

Motor tricycles

(L5) and heavy

quadricycles

(L7)

UN/ R40

Type 1:

Exhaust

emissions at

ambient

conditions

UDC (warm)

Chassis

dynamometer;

driving cycle

has 1 part;

warm start (2

parts to warm,

6 parts to

measure

emissions);

OVC vehicles

tested in two

conditions

(Condition A –

fully charged

and Condition B

– minimum

charge)

CO; HC; NOx

(Euro 3)

In g/km

Different

emission levels

for positive

ignition and

compression

ignition, no

extra-urban

driving cycle

117


Regulation Type and power band


Positive

injection only

Two- or three-

wheeled motor

vehicles

[Motorcycles

(L3 & L4), and

motor-tricycles

(L5). Also

assumed to

include

quadricycles

(L7)]

Type 2:

Exhaust

emissions at

ambient

conditions

At normal idle

OR

Performed

immediately

following test 1

Only one test is

required

OVC vehicles

tested in two

conditions

(Condition A –

fully charged

and Condition B

– minimum

charge)

CO

in % of volume

of total

emissions

Engine speed

in min-1

(Euro # is n/a)

No limits

Recorded for

information only

No clause for

start-stop

systems or

hybrids which

stop the engine

is given

Type 2:

Exhaust

emissions at

ambient

conditions

At high idle

(> 2,000 min-1)

Directive

97/24/EC with

reference to

95/1/EC

Compression

ignition only

Two- or three-

wheeled motor

vehicles

[Motorcycles

(L3 & L4), and

motor-tricycles

(L5). Also

assumed to

include

quadricycles

(L7)]

Opacity of

emissions:

Steady-state

operation test

over the full

load curve

using engine

Net power test

from Directive

95/1/EC

Chassis or

engine

dynamometer

Measured with

engine at full

load and steady

state at 6

engine speeds:

max, min, max

power, max

torque, and two

others

Light-

absorption

coefficient

Flow rate

No exceptions

for a hybrid

vehicle are

given.

This does not

explicitly state

four-wheeled

motor vehicles

such as

quadricycles

However,

quadricycles

are mentioned

within the text,

wording may

have been

chosen to

prevent

confusion with

N & M vehicles

Opacity of

emissions:

Free-

acceleration

test

Chassis or

engine

dynamometer

With engine in

neutral, the

throttle is

applied in a

steady motion

until maximum

speed is

achieved and

then allowed to

return to idle

118


WLTC for Class 3 vehicles Annex E

The following graphs show the test cycles to be used for Class 3 vehicles. The figure numbers are as per the draft GTR (30.06.2013). Figure 1 WLTC, Class 3 vehicles, phase Low3

0

20

40

60

80

100

120

140

0 60 120 180 240 300 360 420 480 540 600

vehi

cle

spee

d in

km

/h

time in s

WLTC,class 3 vehicles, phase Low3

119


Figure 2 WLTC, Class 3 vehicles, phase Medium3-1

Figure 3 WLTC, Class 3 vehicles, phase Medium3-2

0

20

40

60

80

100

120

140

600 660 720 780 840 900 960 1020

vehi

cle

spee

d in

km

/h

time in s

WLTC, class 3 vehicles, phase Medium3-1

0

20

40

60

80

100

120

140

600 660 720 780 840 900 960 1020

vehi

cle

spee

d in

km

/h

time in s

WLTC, class 3 vehicles, phase Medium3-2

120


Figure 4: WLTC, Class 3 vehicles, phase High3-1

Figure 5 WLTC, Class 3 vehicles, phase High3-2

0

20

40

60

80

100

120

140

1000 1060 1120 1180 1240 1300 1360 1420 1480

vehi

cle

spee

d in

km

/h

time in s

WLTC, class 3 vehicles, phase High3-1

0

20

40

60

80

100

120

140

1000 1060 1120 1180 1240 1300 1360 1420 1480

vehi

cle

spee

d in

km

/h

time in s

WLTC, class 3 vehicles, phase High3-2

121


Figure 6 WLTC, Class 3 vehicles, phase Extra High3

0

20

40

60

80

100

120

140

1460 1520 1580 1640 1700 1760

vehi

cle

spee

d in

km

/h

time in s

WLTC, class 3 vehicles, phase Extra High3

122


Car labelling Annex F

Car labelling in the European Union Car labelling was first introduced in the Directive 94/1999, which related to the availability of consumer information on fuel economy and CO2 emissions for new passenger cars. The purpose of the Directive was to properly inform prospective consumers on their options (for buying or leasing) regarding the aforementioned criteria. ADAC presented in 2005 the existing labelling schemes in Europe. Some indicative schemes are presented in the table below, depicting the indicators and the way of their presentation. Table 1 Examples of existing national schemes (ADAC, 2005)

Labelling example Country

Belgium

The Belgian scheme includes seven energy

efficiency classes (CO2 emission bands).

Additionally, it presents:

The fuel consumption

CO2 emissions

Text on the importance of regular maintenance

to keep fuel consumption and CO2 emissions

low

Portugal

The Portuguese scheme comprises of four

energy efficiency classes (CO2 emission

bands), including numerical data of fuel

consumption and CO2 emissions. No other

information is provided.

123


United Kingdom

The UK scheme includes six CO2 emission

bands. Besides the numerical data on fuel

consumption and CO2 emissions, the UK label

includes also further information regarding

economy and environment-friendliness of the

vehicle model:

Graduated vehicle excise duty VED

(Pound/year)

Fuel cost (Pound) for a driving distance of

12,000 miles, estimated fuel price per litre:

petrol 76 p (1.10 €), diesel 78 p (1.13 €), LPG

38p (0.55 €).

Denmark

The Danish scheme presents seven CO2

emission bands, the fuel consumption and the

CO2 emissions indexes. Additionally, it includes

further information on:

“Green motor tax” (Kr/year)

Fuel cost (Kr/year) for a driving distance of

20,000 km, estimated fuel price per litre: petrol:

8.25 Kr (1.07 €), diesel 7 Kr (0.91 €)

EuroNCAP frontal-/side impact rating (1-5 stars

”*”)

EuroNCAP pedestrian test rating (1-5 stars ”*”)

Particle filter (yes/no).

Other European countries with car labelling schemes40 are: the Netherlands, Spain (optional) and Switzerland. Each country presented different labels in terms of additional information (e.g. costs), the definition of the CO2 bands (number of bands and band ranges) and the calculation of the presented ranges. Car labelling in the United States (US) Also in the United States car labels are applied. The textbox below depicts some examples from the US regarding labels for HEVs and EVs. The National Highway Traffic Safety Administration (NHTSA) and the Environmental Protection Agency (EPA) have issued new requirements for a fuel economy and environment label that will be posted on the window sticker of all new automobiles sold in the U.S. The redesigned label provides expanded information to American consumers about new vehicle fuel economy and fuel consumption, greenhouse gas and smog-forming emissions, and projected fuel costs and savings, and also includes a smart phone interactive code that permits direct access to additional web

40 These schemes are relative; the Netherlands and Spain use relative comparison systems based on the vehicle size (defined by the vehicle floor space) while the Swiss comparison system indicates the energy efficiency classes in relation to the vehicle weight

124


resources. More specifically, labels for advanced technology vehicles (hybrids and electric vehicles) will include: • Driving Range: Identifies how many miles EVs (electric vehicles), PHEVs (plug-in hybrid electric

vehicles), FCVs (hydrogen fuel cell vehicles), and CNG (compressed natural gas) vehicles can drive before recharging or refuelling.

• Charge Time: Identifies the amount of time it takes to charge EV and PHEV batteries. • Different Modes: Some vehicles, such as PHEVs, may have two or more different operating

modes – such as all-electric, blended gas and electric, and gasoline-only. The labels will provide certain information for different operating modes.

• Fuel Economy: The label shows fuel economy for advanced technology vehicles in miles per gallon of gasoline-equivalent (MPGe). A gallon of gasoline-equivalent means the number of kilowatt-hours of electricity, cubic feet of CNG, or kilograms of hydrogen that is equal to the energy in a gallon of gasoline.

• Energy Consumption Measurement: Fuel consumption is expressed as a unit of fuel purchased (e.g., kilowatt-hours) per 100miles.

Figure 6.1 Example of label for advanced technology vehicles - EV

125


Evaluation of car labelling The different ways of information provision by car labelling have been evaluated. The LowCVP Car Buyer Survey (LowCVP, 2010) aimed at firstly ascertaining the relative importance of environmental issues at point of purchase, and secondly and thirdly at identifying the most readily understood vehicle environmental metrics and the most effective presentation of vehicle environmental information. The survey comprised of multiple focus groups as well as an online web-based survey. As part of the survey, participants were presented with UK- and US-style fuel economy labels for the same model, and split accordingly over which label they prefer. Participants who supported the UK-style label responded well to its colour coded A-M bands as currently used. On the other hand, those who supported the US-style fuel economy label liked the fact that it links clearly with fuel

Figure 6.2 Example of label for advanced technology vehicles - PHEV

The format of the labels in the US has some degrees of flexibility. The final format of the Nissan Leaf electric vehicle is shown below. Note that the range of a fully charged battery is 73 miles instead of the average 100 miles as claimed by Nissan. Figure 6.3 Nissan Leaf (EV) official showroom label in the US

126


economy, which was displayed in large type. Furthermore, while the term ‘combined’ driving condition was generally understood, ‘city’ and ’motorway’ were much preferred to ‘urban’ and ‘extra-urban’ as it appeared on the UK label. For a future EU fuel economy label, the LowCvp recommended considering adding ‘best in class’ information (with a focus on ‘best in class’ fuel economy), while balancing the possible benefits of doing so with the equally important risk of overloading consumers with too much information.

127


Consumers’ survey Annex G

Table 1: Survey clusters and parameters

Category Description Unit Fuel/energy

consumption and

driving range

Fuel/ electric energy consumption for city/urban

driving conditions

(litre per 100 km or

kilowatt-hours

(kWh) per 100 km)

Fuel/ electric energy consumption for

highway/non-urban driving conditions


kilowatt-hours

(kWh) per 100 km)

Fuel/ electric energy consumption for average

driving conditions (combination of urban/non-

urban)


kilowatt-hours

(kWh) per 100 km)

Electric-only driving range of the car in standard

weather and road gradient conditions (no use of

air conditioning and flat roads)


kilowatt-hours

(kWh)

Electric-only driving range of the car in severe

weather conditions (large difference between

cabin and ambient temperature in

winter/summer, requiring air conditioning

switched on)

(km in

electric/battery

mode)

Electric-only driving range of the car in severe

road gradient conditions (hills and mountain

driving)

(km in

electric/battery

mode)

Ancillary fuel/electricity consumption from

additional weight/load (such as extra passengers,

baggage, etc.)

percentage of

additional fuel/

electric energy

consumption (%) or

percentage loss of

electric-only driving

range (%)

128


Category Description Unit Financial

Purchase price of the car including taxes and

subsidies

(€)

Gasoline (petrol, diesel, other) or electricity price (€)

Annual motor / circulation taxes (€)

Depreciation and resale value (€)

Battery and

recharging

Lifetime of the battery (number of

recharging cycles,

number of

kilometres driving

before

replacement)

Battery recharging time in standard mode (slow

charging from regular electrical socket)

(hours)

Battery recharging time in fast charging mode

(fast charging using a special multi-pin socket)

(hours)

Recharging capabilities (home charging,

fast charging,

wireless charging,

battery swap)

Availability of recharging points (numbers, density,

locations)

Performance

Acceleration of the car (seconds to 100

km/hour)

Maximum speed of the car (km/hour)

CO2 emissions and other pollutant emissions (grams per km)

129


Category Description Unit

Car size/capacity (number of seats,

volume)

Noise (decibel inside

and/or outside the

cabin)

Comfort (value adding add-

ons, driving

experience,

functionality)

Safety (NCAP rating, fire

risks, high voltage

risks)

User related factors

Car brand (brand loyalty,

brand preferences)

Car design (design

preferences)

Figure 1: Age distribution

130


Figure 2: Gender distribution

Table 2: Parameters’ ranking per country

Country UK DE FR NL BE Overall

Fuel/ electric energy consumption C/U 11 4 8 15 10 11

Fuel/ electric energy consumption H/ nU 12 3 11 13 12 12

Fuel/ electric energy consumption AVG 10 2 5 12 11 7

Electric-only driving range of the car in StW 20 13 19 19 18 16

Electric-only driving range of the car in SW 19 12 18 20 20 16

Electric-only driving range of the car in SR 18 17 17 21 22 21

Ancillary fuel/electricity consumption 15 15 20 21 17 20

Purchase price 3 1 1 2 1 1

Price 6 5 6 8 8 6

Annual motor / circulation taxes 9 8 16 9 5 10

Depreciation and resale value 16 21 21 14 18 19

Lifetime of the battery 1 7 4 5 5 4

Battery recharging time in SM 6 11 14 7 7 8

Battery recharging time in FCM 8 14 13 6 9 9

Recharging capabilities 4 10 9 3 4 5

Availability of recharging points 1 8 3 1 3 2

Acceleration of the car 24 24 23 25 24 25

Maximum speed of the car 23 23 25 23 25 23

CO2 emissions 17 19 12 18 15 15

Car size/capacity 14 18 6 10 14 14

Noise 22 20 15 16 16 18

Comfort 13 16 10 11 13 13

Safety 5 6 2 4 2 3

Car brand 24 25 24 23 23 24

Car design 21 22 22 16 21 22

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• Abbreviations C/U: City/ Urban driving conditions H/ nU: Highway/ non-urban driving conditions AVG: Average driving conditions (combination of urban and non-urban) StW: Standard weather and road gradient conditions (no use of air conditioning and flat roads) SW: Severe weather conditions SR: Severe road gradient conditions SM: Standard mode FCM: Fast charging mode • Other notes Purchase price: purchase price of the car including taxes and subsidies Price: Gasoline (petrol, diesel, other) or electricity price Ancillary consumption: from additional weight/load CO2 emissions also include other pollutant emissions Results per country The key findings are presented as follows. UK respondents gave the highest scores for the battery and recharging, together with safety. The main interest of the UK respondents is the battery and recharging characteristics. Compared to the other countries, the UK shows the highest interest in the depreciation and resale value, and scores moderately low in the energy consumption parameters and quite low in the rest of the performance and the user related indicators. German respondents demonstrates a different distribution of consumer preferences. Prices and energy consumption parameters determine the first five in the score. The interest of German respondents is focused on the fuel prices (fuel and electric), followed by the safety parameter and then the range and recharging capabilities. The French respondents’ preferences are more evenly distributed among all clusters: the buying price, safety, the availability of charging points, the battery lifetime and the average energy consumption. Additionally, the French respondents showed a higher interest in performance parameters then respondents from other countries. Compared to the other countries the French respondents show the least interest regarding the annual taxes. The recharging attributes (capabilities and access points) and the purchase price are the highest ranked parameters among the Dutch respondents, followed by the safety and the lifetime of the battery. The rest of the battery attributes followed by the financial indicators also score quite high in the preferences. Moderately score the energy consumption variables as well as the performance ones. In fact, the Dutch respondents were the most indifferent of all respondents regarding all energy consumption indicators. Comfort and capacity are within the interest of the Dutch respondents. Finally, they differentiate from the other countries ranking the car design on the 16th position. Belgian preferences are very close to the Netherlands’ ones. Purchase price and safety come first followed by battery and recharging capabilities. The lowest scores are calculated for the electric range, the speed and acceleration and well as the user related attributes.

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Stakeholder reactions Annex H

AECC (Input based on an interview with AECC. Please note that also a paper ‘AECC CONTRIBUTION TO THE CARS 21 PROCESS ON COMPETITIVENESS AND THE SUSTAINABLE GROWTH OF THE AUTOMOTIVE INDUSTRY IN THE EUROPEAN UNION’ was received. This paper is not included in this annex) Introduction AECC expressed the wish to further elaborate on their concerns about the following phase from their input to this study and the CARS21 group. Emissions and CO2 legislation are critical drivers for the future development of automotive technology. As such the legislation needs to continue to be technology neutral, permitting the development of those technologies best suited to the particular applications. Specifically, it needs to ensure a level playing field for all powertrain options to ensure the development of the most appropriate and cost-effective systems. It is not valid to consider only tailpipe emissions if some technologies, such as plug-in electric vehicles, rely on the generation of emissions elsewhere to achieve low or zero tailpipe emissions.

Interview highlights AECC is involved in the CARS21 process. They feel that CARS21 is putting more emphasis on promoting EVs or hybrid technologies than on improving ICE technologies. AECC is convinced that there is still much room for improvement of ICE technologies. However, as long as EVs are considered to be zero-emission vehicles, they feel there is no level playing field. Indirect emissions from electric energy use should be taken into account for a fair comparison between technologies. As UNECE 101 regulation includes a provision (and standardized test procedure) for electric energy use in kW/km, this parameter could be translated into CO2 emissions per km. AECC see a need for the EC to provide a common approach and calculation formula for this conversion of kW/km into CO2/km. AECC prefer this figure to be based on the average CO2 intensity of the European electricity mix, rather than to differentiate this by country. The central philosophy behind AECC’s position is that zero-emission EV’s or hybrids in EV mode are in reality no zero emission vehicles. A level playing field is key to the business case of CO2 mitigation in ICE technologies. ACEA (Input as received from ACEA, please note that the mentioned lList of definitions related to the electrified vehicles is not included in this annex)

ACEA draft proposal in terms of Recommendations and need of clarification along with TRL/Ecorys (EU E-lab program)

1) Type-approval based on a technically neutral test procedure

Here is the current state of play on electrified vehicles, which are a growing part of the vehicle fleet.

At the present time, all of the performance criteria and electric concepts cannot be known exhaustively and fully detailed/described.

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Electrified vehicles means41 :

• EV (Electric Vehicle). • FCEV (Fuels Cell Electric Vehicle). • FCHEV (Fuel Cell Electric Hybrid Vehicle). • HEV (Hybrid Electric Vehicle). • PHEV (Plug-in Hybrid Electric Vehicle). (Range Extender vehicles (RE) are part of the group PHEVs and have 2 main characteristics: full electric capability and use of electric propulsion as long as battery energy is available).

To assess the performances of these main vehicles categories, we have a set of main criteria, such as: electric ranges (AER, AER city, EAER, Rcda42) , which help the customers to compare electrical vehicles with regards to the operation strategies.

41 See Annex part: list of definitions developed in the frame of the WLTP activity (DTP_E-lab group) 42 See the draft definitions list for the WLTP GTR (updated version). Electric ranges are taken as an example.

Landscape Of Powertrain Configurations

ElectricEngine

InternalCombustion

Engine

Power of ICE Power of electric engine Diameter proportional to powerDiameter proportional to power

Ran

ge +

Range Extender(Low ICE power)

ElectricVehicle

(EV)

PluginHybridElectricVehicle(PHEV)

HybridElectricVehicle(HEV)

Zone of partially zero

emissions

Fuel cell

Range Extender

(Medium ICE power)

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See the following matrix as an example:

AER

AER

city

*

EAER

Rcd

a

Fuel

con

sum

ptio

n

CO

2

Elec

tric

con

sum

ptio

n

EV high high = AER =AER 0 0 x

Lower

power EV

low medium =AER city* = AER city* 0 0 x

Range Ext high high = AER =AER x x x

PHEV high/ medium high/ medium > AER > AER x x x

Lower

power

PHEV

low medium >AER city* > AER city* x x x

HEV N/A N/A N/A N/A x x N/A

FCEV N/A N/A N/A N/A x 0 0

Plug-in

FCEV

high/ medium high/ medium > AER > AER x 0 x

FCHEV N/A N/A N/A N/A x x N/A

Plug-in

FCHEV

high/ medium high/ medium > AER > AER x 0* * x

*for city test condition (to be defined in the frame of DHC) N/A : Not Applicable * * ICE fuelled only with H2

2) Type approval data that could be used for providing customer information.

Here is the current set of criteria based on certification data:

• electric ranges (NB: electric range is only related to the full battery condition). • electric consumption. • fuel consumption. • CO2 value. • pollutant emissions stage (i.e. Euro x).

3) Additional customer information.

Additional information should be considered in a framework of standardisation in order to develop appropriate methods to determine some key new parameters, such as:

• Pure customer information: - Charging time. - Ancillary loads.

• Customer and car manufacturer relationships: - Durability of the battery (see Annex). - Maintenance parameters (specifically related to life of major components, e.g. battery pack).

Such additional customer information is the responsibility of the manufacturer and in the manufacturer’s interest to find out the wishes and aspirations of the customer as best possible, based on standardised criteria.

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• Durability of the Battery :

Japanese experience – current project :

The New Energy and Industrial Technology Development Organization (NEDO) has started in 2010 a project to develop a "Battery Durability Evaluation Procedure" including car industry, battery supplier and so on … The ideal goal of this project is to define a technical standard in 5 years in order to provide appropriate information based on a harmonized test procedure in terms of battery durability not only for the customers who are buying new electrical vehicles but also used ones. There is only discussion for standardization not for a regulation.

• • List of definitions related to the electrified vehicles in the frame of the WLTP activity (DTP_E-lab group) – Draft version

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ACEM (Input as received from ACEM) ACEM, the Motorcycle Industry in Europe, is the professional body representing the interests and combined skills of 13 manufacturers producing a total of 25 motorcycle, scooter, and moped brands. The members of ACEM account for 90% of the production and up to 80% of the European powered two-wheeler market. Introduction Most of the ACEM manufacturers are developing electric two-wheelers, including hybrid, some of them are already on the market. The EU powered two-wheeler (PTW) industry supports the principle of delivering accurate and reliable information to the consumer, with the aim to build up confidence in a new and promising market segment. By steadily doubling registrations every year, today more electric PTWs are sold in Europe than pure electric cars. So far 11.000 units were reported for the first 6 months 2011 compared to last year’s 5567, accounting for 0,3% of the EU market. Contribution to the study 1- Parameters already regulated The following environmental utility parameters are already regulated through the type approval directives 1997/24/EC and its several chapters and 2009/108/EC (for hybrid two and three wheel motor vehicles) • Polluting emissions, • Fuel consumption, • Noise, • Max Power, • Max torque through self declaration, • Weight of battery excluded from the vehicle mass, • Electromagnetic compatibility. The battery directive 2006/66/EC regulates horizontally the mandatory declarations of manufacturers and integrators as well as the end of life of this component. 2- Parameters to be regulated There are several environmental utility parameters which should be regulated by means of standardised test procedures: • Specific tell-tales, • Energy consumption in kWh/km from socket to wheel in fast and normal charging modes, • Range, • Electrical functional safety. It should be noted that most of these parameters are covered by the ISO DIS 13063, a standard specifically developed for PTWs to be adopted by the beginning of 2012. 3- Reasons for whether or not to be in favour of standardised procedures The consumers can evaluate a product through comparable data measured through standardized procedures. Transparency and comparability of information are prerequisites to build up confidence in the new segment of ePTWs. Additionally, it allows a clear distinction between low quality and serious products, ensuring level playing field for the manufacturers operating on the market.

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4- Information to consumers The environmental utility parameters that provide key information to consumers when purchasing a Category-L EV/HEV are listed in the below chart. • Electric range: in km (Range in EV mode for HEVs); • Energy consumption: in kWh/km from socket to wheel in fast and normal charging modes; • Performances: max speed in km/h and climbing capability in %; • System voltage: in volts; • Battery type: nature of the components; • Recharge time: in number of hours or minutes; • Maintenance parameters: in owner manual.

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ANWB (Please find below the results of the interview with the ANWB) Interview with Royal Dutch Touring Club ANWB (1-8-2011) Intro ANWB The Royal Dutch Touring Club ANWB offers a wide range of services related to roadside assistance and medical and repatriation assistance abroad, legal assistance, travel, information products, insurances, selling travel related products, and many other products and services in the areas of recreation, tourism and mobility. Furthermore, the ANWB is active in lobbying in the fields of car driving, mobility, travel and recreation. Role in introduction electric vehicle ANWB tries to get a strategic role during the start-up phase of the electric vehicle. The interest of ANWB is in a few different subjects: • The introduction of electric vehicles has consequences for roadside assistance. It is unsure that

if roadside assistance is possible for electric vehicles. The motor has few “moving parts”, so problems tend to be computer based or electronically based. Furthermore, there might be a safety issue for the roadside assistant.

• ANWB is concerned on general safety issues and participates in crash tests of electric vehicles. • ANWB provides information to its members regarding car ownership costs and the

environmental impact of cars. The organization wants to include electric cars in such lists, and is currently looking for tools to make a fair comparison with fossil fuel cars.

• ANWB is a “for profit” organization which invests halve of their profits in public initiatives. One of these initiatives the organization is interested in is the building of fast loading points.

ANWB has recently purchased 5 electric vehicles, partly to conduct tests and partly for the image of the organization. View on the Dutch electric vehicle market • Until 2012: “pioneering phase”.

- Establish loading protocols and standardization - Solving safety issues - “Show public that it’s feasible”

• Between 2013 and 2015: Introduction into business market: - Decisions are made on costs, not emissions. - Electric vehicle in city:

• Taxis • Public transport • “Green Wheels” • Postal services • Funeral services

• Plug-in hybrid for Dutch lease market: - Fiscal incentives: “0% value to be added to taxable income”

• 2015 and on: slow introduction into consumer market - Estimation that total from 2015 onwards total ownership costs are equal to fossil fuel

vehicles. Information requirements for consumers ANWB makes a distinction in information that consumers require in the showroom and additional background information. Showroom information will convince consumers to buy an electric vehicle.

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The background information will not directly pop into the consumers mind, but will play a role in case there is uncertainty regarding the issues. • In showroom

- Price - Convenience - Availability

• Background - CO2 (well to wheel) - Safety

Price • To convince consumers to buy EVs, insight must be given to total cost of ownership (TCO) • ANWB will develop a tool for this. • Important issue is the residual value of the EVs

- Batteries (€ 20.000) are depreciated fully after 3 years. - The units however still have 20% capacity left after 3 years, and can have a second life in

for instance boats or wind mills. • Other important issue is the comparison between electric cars: The total maximum travel

distance of vehicles can be the same (for instance 160 km), but the total energy usage on that trip can be different. This should be reflected in the information availability.

Convenience • Good insight in the total driving range is crucial.

- Information is needed for a broad range of circumstances, such as traffic situation, weather, Gradient, etc.

- Should be available through the board computer. To avoid stress, people should be able to rely on this computer that they will make it to their destination.

- Current tests (city/ other) are not sufficient. • Standardization of plugs • Interoperable pay system. A subscription service where abroad costs are much higher than in

the Netherlands (as with mobile phones) should be avoided • Plugs should be secured (other people should not be able to unplug your car). Loading points

should be “bug free” (cases happened that the loading point was unwilling to unplug) Availability • Enough loading points should be available. CO2 • A good CO2 comparison tool should be developed, in order to be able to compare EVs with

other vehicles • Much uncertainty in ANWB what calculation steps should be taken to include Well-to-tank

emission. Is there a common standard? • There is need for a method to involve the negative environmental impact of the fabrication of

batteries? • There is a huge difference between test emissions and the common practice. This is especially

the case for energy efficient vehicles. For instance: Testing of a Plug-in hybrid car are assuming that the car batteries are always loaded. Lease drivers who only purchase them for the fiscal incentive might never use the batteries.

Safety • Safety of loading points

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• Safety of driver after a crash • Safety of emergency personnel and helping bystanders

- Not always clear whether a vehicle is an EV and if there is still voltage - Kill switch should be reachable from the outside.

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CENEX (Input as received from CENEX. Please note that the mentioned papers are not included in this annex.) Dear Sir

Cenex, the UK’s first Centre of Excellence for Low Carbon and Fuel Cell technologies, is actively

conducting user trials and evaluating EV performance in both real world and laboratory conditions.

Our work focuses on both technical performance and consumer and fleet attitudes towards EVs.

Due to the limited amount of stored energy currently available in a pure EV, more accurate

information regarding EV range are required at the point of sale. The current range declaration

used by manufacturers can lead to inappropriate duty selection for electric vehicles and hence

disappointment in EV performance. Cenex would like to present some outputs of its work that

may be useful for your study on test procedures for electric and hybrid vehicles – energy

consumption, utility, range, and impact of A/C etc.

Information regarding range

Cenex’s comparisons of real world and laboratory range assessment have identified the Artemis

cycles as being broadly representative of the range users experience in real world conditions. The

chart below shows the range variation of two electric vehicles, the smart EV and Mitsubishi i_MiEV,

over the three Artemis drive cycles (Motorway, Urban and Rural). The Mitsubishi data also shows

the difference between the three driving modes available for user selection ‘Drive (D)’, ‘Eco’ and

‘Brake (B)’.

This data compares to an R101 range for the smart and Mitsubishi being 142 and 116 km

respectively over the regulated NEDC (independently tested by Cenex). EV performance over

different driving cycles is covered in more detail in Cenex’s EV range testing presentation available

at http://www.cenex.co.uk/LinkClick.aspx?fileticket=L2mk6XhufzQ%3d&tabid=119&mid=695

Information regarding use of Ancillary Loads

Cenex conducted it’s ‘Smart Move 2’ EV user trial over six months that incorporated autumn and

winter 2010/2011. During this period, users experienced some very low EV ranges and driving

temperatures. The chart below shows the energy consumption and ambient journey temperatures

recorded from six electric smart cars distributed throughout the UK. Here we can see a clear

correlation between journey efficiency (km / %SoC used) and ambient temperature.

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http://www.cenex.co.uk/LinkClick.aspx?fileticket=L2mk6XhufzQ%3d&tabid=119&mid=695

Subsequant analysis of the data showed that the Li-ion battery capacity during the trial was not

significantly effected by the cold temperature, however regen preformance was reduced and most

significantly the cabin heating load was high. Practically this meant that a vehicle purchased by a

consumer/fleet was unable to complete the same duty cycle in winter and summer. The reduction

in range due to auxillary heating demand between vehicles is dependent on the absolute battery

capacity, the energy efficency of the vehicle (km/kwh) and the heating technology incorportated and

therefore a blanket range reduction percentage to represent winter auxillary loads would not be

appropriate. It is Cenex’s opinion that auxillary power efficiency should be part of the consumer

information available when purchasing an EV. Further information on the winter performance of

EVs and consumer purchasing incentives is available in the paper below.

Cenex is continually expanding its knowledge and benchmarking of the performance of modern

electric vehicles. A library of our publically available electric vehicle studies and papers are

available for download from the resources section of our website http://www.cenex.co.uk/resources

Please do not hesitate to contact us if we can be of further assistance.

Yours sincerely

CENEX Holywell Park (Garendon Wing) Loughborough University Ashby Road Loughborough LE11 3TU www.cenex.co.uk Switchboard - 01509 635750

Nov’10 Dec’10 Jan’11 Feb’11 Mar’11

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http://www.cenex.co.uk/resources

http://www.cenex.co.uk/

European Garage Equipment Association (EGEA) and Automotive Aftermarket Distributors (FIGIEFA) (Input as received from EGEA and FIGIEFA)

Brussels, 22nd June 2011 EGEA/FIGIEFA contribution to the Commission study on type ap-proval test procedures for electric (EV) and hybrid electric vehicles (HEV) “Open reparability” for all electric and hybrid electric vehicles EGEA43 and FIGIEFA44 welcome the Commission’s initiative to launch a study on type approval test pro-cedures for electric (EV) and hybrid electric vehicles (HEV) to support the revision of specific type approval test procedures related to emissions and the environment utility of EV and HEV with a view to the ongoing work for the new WLTC and/or European complementary legislation. EGEA and FIGIEFA would hereby like to contribute to this study and current debate on this issue by a few remarks on the importance of the principle of “open reparability” of these vehicles. Affordable mobility for European citizens is crucial and largely depends on the motorists’ ability to have their vehicles serviced and repaired at reasonable cost, and this throughout the entire life-cycle of a ve-hicle. This is also true for vehicles equipped with cleaner next generation power trains such as electric vehicles, and it is most crucial that an adequate and adapted infrastructure will be put in place for repair shops and the many other service providers in the automotive aftermarket. Any future technological developments in electric and hybrid electric vehicles will require major adapta-tions in the repair and maintenance of these vehicles. Independent, multi-brand market operators play a vital role in providing efficient and competitive after-sales services, provided that they have open, non-discriminatory access to training, multi-brand test equipment, technical information, and replacement parts. As it has been the case in the Euro 5/6 type-approval legislation (Regulations N° 715/2007 and 692/2008), the European Commission is invited to make sure that “open reparability” is also en-sured for electric and hybrid electric vehicles, to affirm this principle and to adapt the technical specifications in any future piece of type-approval legislation. The existing Framework Directive does not contain any provisions on access to technical information, but EVs and HEVs have technical particularities, which would require respective technical specifications and adaptations in the European type-approval legislation. Subject to more detailed input, EGEA and FIGIEFA would hereby like to give some preliminary indications: Ensure competitive and safe vehicle repairs • Access to Repair and Maintenance Information is crucial for all independent operators.

43 Founded in 1980, the European Garage Equipment Association regroups 11 national professional associations representing the interests of both manufacturers and importers of garage and test equipment

44 Founded in 1956, FIGIEFA is the international federation of automotive aftermarket distributors. Gathering 26 national trade associations from 23 countries in Europe, FIGIEFA represents the interests of both independent spare parts distributors and in-dependent repairers organised in repair chains. FIGIEFA's key objective is to safeguard free competition in the aftermarket at European and international level.

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• Transfer and adaptations, if necessary, of all requirements regarding repair and mainte-nance information from Regulations N° 715/2007 and N° 692/2008 into the new legislation for EVs and HEVs, e.g. for re-programming and diagnosis of all ECUs by using the standards de-fined in the Euro 5/6 regulations (SAE J 2534, ISO 22 900-2).

• Access to technical information for garage and test equipment manufacturers For workshop equipment suppliers, technical information is necessary for various equipment designs and applications to ensure that independent operators can provide competitive and safe vehicle repairs. • Access to in-vehicle remote diagnostic systems to independent operators Vehicles equipped with telematics systems have increased in the last few years. Telematics systems are connected to the diagnostic system of the vehicle and can therefore be seen as a further diagnostic access to the vehicle. Access to these systems is nowadays crucial for the servicing and repair of modern vehicles. As electric and hybrid electric vehicles will contain such features, and with view to ensure that vehicle owners have a free choice of the service provider, it is crucial that the telematic control units are accessible also by independent operators. Better clarification of the following terms • We hereby invite the European Commission to give further clarification and to accurately define

the following systems in the vehicle: a) Start stop systems b) Hybrid systems - Without mechanical separation of combustion engine/electric engine - With mechanical separation of combustion engine/electric engine c) Range extender (including fuel cell) d) Pure electric vehicles (without on board power generation) Some of the above-mentioned systems are already defined in the current Framework Directive for the type-approval of motor vehicles 2007/46/EC. However, we believe that further clarifica-tion is needed.

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European Federation for Transport & Environment (Input as received from European Fedration for Transport & Environment) Commission study on type approval test procedures for electric (EV) and hybrid electric vehicles (HEV) European Federation for Transport & Environment – response to call for stakeholder input Ref: ENTR.F1/KS D(2010) Environmental and utility parameters – T&E comments 0- Summary and key points Information provided to the consumer should be complete, truthful and accurate, in particular with a view to representing real-world usage and enabling fair competition with all vehicles placed on the market. This includes fair representations of range, costs and emissions. Current technical definitions including UNECE regulation 101 do not provide sufficient representative data and the related scope and requirements should therefore be expanded. 1- General comments Within a broad portfolio of current and future low-carbon automotive technologies, Electric and Hybrid-Electric vehicles are promising options which could play a key role in delivering on Europe’s decarbonisation strategy for both the transport and energy sectors. In particular, these vehicles may represent an important avenue to lower the CO2 emissions of Europe’s vehicle fleet. EVs and HEVs are rapidly reaching market maturity, highlighting the need for timely development of standards and procedures, in particular regarding accurate, complete and truthful customer information. In this context T&E welcomes the Commission’s work on the revision of type-approval procedures for these vehicles and the opportunity to contribute to this development. Electric vehicle technologies are still in an early stage of development and in many cases do not yet meet customer expectations. In the light of their potential contribution to transport decarbonisation, early-stage incentive measures have been introduced to accelerate their broader adoption (such as the introduction of supercredits in regulation EC443/2009). Meanwhile, type-approval data on conventional vehicles is also coming under increased scrutiny as the published figures rarely match actual customer experience. In this context T&E would like to reiterate the need (for EV/HEVs but also conventional vehicles) to establish a level playing field and provide accurate type-approval information representative of real-world driving conditions on all vehicle types in order to allow competitively fair market behaviour and ensure the proper functioning of the internal market. Our specific comments on consumer requirements are laid out below. 2- Consumer requirements The automotive market is set to face increasing diversity in coming years in response to the combined pressures of energy costs and environmental impacts. As a result, customers will be faced with ever-more complex choices to satisfy their mobility needs in accordance with their budget and environmental concerns. It is paramount to ensure that sufficient information is provided to enable these choices. Our general principle is to favour transparency and that wherever technical information is known to the manufacturer or type-approval authority, it should be made accessible to the customer. As most customers will only focus on the main characteristics of the vehicle, some data will have to be more 2 prominently displayed or given priority in product documentation (label, promotional material, user’s manual) and we also outline below which critical information should be mandated.

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3- Consumer information In the section below, we first describe which parameters should be determined by type-approval procedures, then focus on how these would apply to different categories of vehicles. (Our focus here is mostly on the parameters which we anticipate would be specific to EVs/HEVs as opposed to other modes of propulsion). Many parameters are already available and determined by current regulation UN/ECE-101. Where appropriate, these are mentioned below. However, these are in many cases insufficient or inappropriate to provide accurate information interpretable by the consumer, therefore additional definitions would be required.

3.1. Electrical consumption and range 3.1.1. Battery energy vs. useable battery capacity at end-of-life (kWh)

Current specifications include total battery energy (in kWh). However, modern traction batteries regulate the power draw in use and a variety of other parameters through a battery management system (BMS) to improve battery life and performance. An additional useful metric for the consumer is therefore the total useable span of battery energy, preferably at end-of-life (e.g. expiry of the battery warranty period), not beginning-of-life. This figure (kWh) should be clearly displayed.

3.1.2. Electrical consumption for traction Baseline energy consumption (kWh/km) at average speed and top speed (max 30-minutes speed) are available from current TA tests and should be explicitly displayed.

3.1.3. Electrical consumption of ancillaries (‘hotel loads’) in kW For the sake of comparability, current test procedures greatly simplify the operation of EVs/HEVs. However, non-traction energy-using components on board can represent a significant proportion of energy use. Moreover, these factors can have a different influence on real-world consumption than for equivalent conventional (ICE) vehicles, e.g. heating load. As test procedures are currently being revised for all types of vehicles, it will be important to include these characteristics in comparable format for all types of powertrain. In the meantime, it would be feasible to define a procedure to determine the power of major on-board energy consumers (‘hotel loads’) and reflect these in a concise format (average kW): • HVAC (based on a defined ΔT between ambient and cabin temperature, at several operating

points) • Lighting, steering and other drive-critical ancillaries Other optional power consumers e.g. entertainment and satnav may be more model-specific and should probably be reviewed at a later stage.

3.1.4. Electric range Based on the above considerations, it seems critical to offer complementary information on top of the baseline electric range currently determined under Annex 9 of UN/ECE 101. This could include, for instance: • A best-case electric range as currently determined according to Annex 9 • An average electric range based on the above with the additional inclusion of typical loads

(moderate HVAC, steering, lighting) • A worst-case electric range e.g. under severe weather conditions at high speed.

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In addition to 3.1.2 above, these considerations also apply to the determination of best / average / worst electricity consumption in kWh/km which will be a critical metric to display.

3.2. Consumer usage Consumer experience of driving an EV may prove significantly different from conventional drivetrains. Therefore, to facilitate adoption and respond to consumer expectations, the following specific information should be included:

3.2.1. Recharging capability, i.e. various methods of recharging the vehicle including 3.2.1.1. Home charging (e.g. 16A max) 3.2.1.2. Fast charging 3.2.1.3. Wireless charging pad 3.2.1.4. Battery swap, other… 3.2.2. Recharging times: for each of the above, maximum charge time from fully depleted 3.2.3. Recharging rate in km/minutes or min/km (based on average consumption), which is important from the consumer’s perspective i.e.: how long is the wait to drive a given distance. 3.2.4. Noise

Although beyond the focus of the present analysis, maximum noise values (for both electric and ICE modes if appropriate) should also be included.

3.3. Cost and CO2 emissions Accurately determining real-world CO2 emissions will become increasingly critical as the number of EV/HEVs increase and start having an impact on macro-level energy and greenhouse gas impact. The distinction between BEV/PHEV/HEVs is most critical in this respect. As outlined in the initial scope of work from TRL/Ecorys et al., the distinction which will be of actual importance when considering fuel costs/CO2 emissions is the ultimate energy feedstock, i.e. we can distinguish three categories of vehicles which are slightly different from the current UNECE distinction: a) Vehicles whose sole energy source is a fluid fuel (incl. both ICEVs and NOVC-HEVs) b) Vehicles whose sole energy source is an electricity storage device (pure EVs aka BEVs) c) Vehicles who combine characteristics of the above (PHEVs aka OVC-HEVs) Category a) and b) vehicles are, to a certain extent, simpler to consider from a cost or CO2 perspective as their long-term energy consumption is attributable to only one source of energy. The most difficult procedure regards category c) or PHEVs where assumptions have to be made regarding the respective share of each energy source. On this basis, there also seems to be little practical interest in distinguishing between PHEVs and range extenders. By and large, our major comment on this issue is the following: the calculation of a mixed-mode figure for consumption/CO2 is based on a number of assumptions which are unlikely to be fully transparent to consumers. Therefore, we consider that electric-only and fuel-only figures would be more transparent and should be displayed prominently. If there is an established need for the calculation of mixed-mode figures, it should be strongly stressed that the assumed average distance between two charges (Dav) used in Annex 8 of UN/ECE101 set at 25km is not representative of actual consumer usage. Mean distance

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between charges should be more representative, e.g. 100-200km. Alternative modes of calculation could, for instance, be based on the maximum range (in km) achievable on a full tank or charge of each mode. Based on the above comments we suggest the following parameters regarding the provision of cost/CO2 information:

3.3.1. Cost (c€/km) Fuel consumption and electricity consumption figures can be used to provide cost information, in combination with generally recognised energy price data (as published by Eurostat) on relevant metrics (typically fuel cost at the pump and off-peak, retail customer electricity cost). It seems relevant to set reference data sources with regular updates, and to allow adjustments at national or even regional level (depending on the fiscally relevant scale). Costs should be provided separately for electric and fluid-fuel operation. There is a high risk that mixed-operation costs will prove highly confusing to the customer and therefore such metric should preferably not be displayed.

3.3.2. CO2 Similarly to cost data, relevant figures representing the carbon intensity of the electricity grid (emissions factor in gCO2/kWh) can be determined. Important factors to be considered will be the geographical scope (national / regional), and whether to consider average or marginal intensity values. These emission factors can then be combined with average electricity consumption (kWh/km) to indicate a representative carbon emissions parameter (gCO2/km). Specific arrangements related to the provision of electricity linked to the sale of the vehicle (e.g. demonstrably leading to additional zero-carbon energy generation) could be used as a basis for different emissions factors for particular vehicles. Mixed CO2 emissions figures currently in use under UN/ECE101 could also be formulated for fiscal reasons provided that the Utility Factor / Dav (or other method) more closely represents real-world usage. 4- Information availability We have summarised the parameters listed above and highlighted (in bold red) which would seem to be the most critical from a customer’s perspective, e.g. specifically for ultimate use on a revised Label document:

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151


Fédération Internationale de l'Automobile (including ADAC) (Input as received from FIA including ADAC) Utility parameter Consumers’expectation Test procedure specifics

Energy consumption HEV: fuel consumption[l/100km]

PHEV: fuel consumption[l/100km] and

electric energy consumption

[kWh/100km and lpetrolequivalent/100km]

EV: electric energy consumption

[kWh/100km and lpetrolequivalent/100km]

NEDC, and later on WLTP

Further details see ECE-R83 and

ECE-R101 future WLTP regulation

(PHEV with max. and min. battery

charge)

Electric autonomy PHEV and EV: pure electric driving

distance in terms of [km],





charge)

Overall range under

standard conditions

Figure in terms of [km] NEDC, and later on WLTP




charge)

Overall range reduction

under winter conditions

Figure in terms of % of overall range

under standard conditions

NEDC, and later on WLTP at e.g.-8o

ambient temperature, heating on,

light on, wiper on. Calculation based

on battery capacity reduction seems

feasible

Overall range reduction

under hot summer

conditions

Figure in terms of % of overall range

under standard conditions

NEDC, and later on WLTP at e.g.

30o ambient temperature, MAC on.

Calculation based on MAC

performance data seems feasible.

Alternative: Upcoming European

Regulation on MAC

CO2 emissions and

pollutants

HEV: emissions [g/km] based on fuel

consumption (tank to wheel or in future

better well to wheel)

PHEV: emissions [g/km] based on fuel

consumption (tank to wheel or in future

better well to wheel)) + electric energy

consumption (well to tank, European

mix))

EV: emissions based on electric energy

consumption (well to tank, European

mix)





charge)

Battery charging time PHEV and EV [h]

Battery fast charging time PHEV and EV [h]

Battery fast charging losses (energyfast charging-

energycharging)/energycharging [%]

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Utility parameter Consumers’expectation Test procedure specifics

Battery durability Figure in terms of vehicle mileage [km]. Definition of battery life end: E.g.

battery capacity falls short of 80% of

new battery capacity

High voltage general safety

High voltage crash safety High voltage parts integrity (including

battery);

High voltage switch functionality. High

voltage switch off display after crash.

Fire risks.

European frontal and side impact

test; USA rear impact test (FMVSS

301)

Electromagnetic

compatibility

72/245/EWG and amendments

2004/104/EC, 2005/49/EC,

20083/EC; 2006/28/EC,

2004/104/EC and 2009/19/EC.

Additional amendments with regard

to high voltage emissions necessary

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Fisker Automotive (Input as received from Fisker Automotive at the 14th of June 2011) Response to Stakeholder Input Request: European Commission on Type Approval Test Procedures for Electric Vehicles and Hybrid Electric Vehicles Fisker Automotive is pleased to have the opportunity to respond to the European Commission as it conducts a study to support the revision of specific type approval test procedures related to emissions and the environmental utility of electric vehicles and hybrid electric vehicles. Fisker Automotive is a privately owned auto manufacturer headquartered in Anaheim, California. Fisker Automotive builds environmentally conscious vehicles with passion, style and performance for the global market. Fisker’s first vehicle is Karma, an electric vehicle with extended range (EVer ™). Our manufacturing partner for the Fisker Karma is Valmet Automotive in Uusikaupunki, Finland. Valmet has a track record of producing high quality, premium automobiles, including manufacturing the Boxster for Porsche. Europe is an important market for Fisker, representing 40 percent of global sales. Fisker is appreciative of the opportunity to comment on this study and would like to remain engaged throughout this regulatory process and future policy-making activities. Introduction The comments presented here refer to a May 18, 2011 letter from the European Commission. The letter made two separate input requests. Fisker will respond to the second input request, due by June 27, 2011, in a separate document. The current document will address the first request, which seeks input on two topics summarized below: 1. Potentially important technological developments (e.g. special types of hybrids) and other

considerations, which should be considered when revising and complementing EV/HEV test procedures.

2. EV/HEV related tests procedures, e.g. related to durability or battery parameters, industry applies on a non-regulatory basis for customer information and which could be a basis forrespective harmonized test procedures at type approval.

Fisker Automotive addresses these two topics in the full comments to follow. On the first topic, Fisker believes there are three major areas of important technological developments that should be considered when revising test procedures: • Proliferation of electrified powertrain configurations • Supplementary new technologies not be captured by traditional drive cycles • New vehicle charging infrastructure On the second topic, we suggest two areas where internal testing may be useful and that could be used to inform type approval test procedures. Technological Developments

Proliferation of electrified powertain configurations • Karma features a new powertrain type: an extended range electric vehicle (EVer™) • Regulations must accommodate growing complexity of powertrain configurations The automotive industry is currently experiencing a proliferation of powertrain configurations with varying levels of electrification – a trend that Fisker anticipates will continue in the future. While the extreme ends of the spectrum are well defined – zero electrification in conventional vehicles on one

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end and full electrification in purely battery-driven vehicles on the other – the range in between is becoming increasingly complex. Future regulatory decisions must be able to accommodate this complexity. Consumers and regulators have struggled with how to categorize these electrified powertrains. One early classification system widely used in the public sphere distinguished between “mild” hybrid systems that were only capable of assisting the internal combustion engine and “full” hybrid systems that could propel the vehicle on electricity alone for certain periods of time. The advent of start-stop systems and series-type hybrid electric vehicles revealed this classification to be overly simplistic. Likewise, defining hybrid electric vehicles (HEVs) and plug-in hybrid electric vehicles (PHEVs) based only on whether they are capable of accepting electricity from external sources is problematic in that it does not account for fundamental differences in powertain configurations. Even a distinction between parallel or series hybrid drive is not straightforward. A number of current hybrid models blend series and parallel operation depending on driving conditions. In contrast, the Fisker Karma features a new type of powertrain: the first true series hybrid vehicle on the market. At no time does the engine ever directly power the wheels. We refer to this configuration as an electric vehicle with extended range (EVer ™). This new powertrain type is not adequately accounted for in test procedure regulations. United Nations Economic Commission for Europe (UNECE) Regulation 83, Annex 14, categorizes hybrid electric vehicles along two parameters: 1) whether the vehicle is Off-Vehicle Charging (OVC) capable or Not Off-Vehicle Charging (NOVC) capable, and 2) whether the vehicle is with or without an operating mode switch. The same categorization is also used in UNECE Regulation 101, Annex 8. This regulation classifies the Karma, a true series hybrid, in the same category as a parallel/series hybrid vehicle even though these vehicles could behave very differently in the real world. Additionally, the operating mode switch category is not clearly defined nor does it account for the various levels of driver control offered by different vehicles. Some vehicles may offer a certain level of control, such as the ability to choose the level of regenerative braking, but may force the driver to deplete the vehicle’s electric range before switching to a blended driving mode. Fisker Automotive’s approach is to empower the driver with a large degree of control over the vehicle’s operating mode. The range-extending engine generates electricity in the Karma’s “Sport” mode and does not operate at all in “Stealth” mode. However, viewing these modes as simply an “EV mode” switch is overly simplistic. The Karma’s “Sport” mode unlocks a higher level of performance. Furthermore, the driver’s ability to select either mode at will allows the driver to better manage the battery’s electricity capacity to suit his or her needs. For instance, if a Karma driver is travelling from a suburb into a dense city with a congestion charge, he or she may choose to save the “Stealth” mode capability until arriving at the city center. Vehicle test procedures should not assume thissame level of control in other plug-in hybrid electric vehicles. Fisker Automotive presents these comments as a precaution for regulators, as we expect the vehicle powertain landscape to only become more diverse and complex in the future. It would be easy to ask for a new test procedure category for each new powertrain type, such as ours, but we recognize this is an unsustainable path. Attempting to account for every powertrain configuration becomes less feasible over time as the variation in both level of vehicle electrification and the level of drivercontrol over vehicle operation increases. Indeed, classifying vehicles into well-defined silos may influence automakers to design vehicles to fall within particular categories in an attempt to earn a particular classification label or maximize performance for a particular test procedure

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category, rather than design the best powertrain configuration for their customers. Fisker does not presume to have the ideal solution to make vehicle test procedures account for this proliferation of vehicle electrification. The preferred regulatory path is one that can characterize environmental performance while remaining neutral to the operational nuances of a particular powertain type. Technologies not captured by test cycles • Supplementary technologies offer real world benefits • Regulation should offer some credit to encourage such technologies Under increasing pressure to reduce fuel consumption and carbon dioxide emissions, automakers may turn to technologies that provide benefits that may not be reflected in current vehicle test procedures. Examples of such technologies include: • solar panels to provide additional electricity • active aerodynamics • a variety of intelligent systems such as efficiency-improving driver feedback, adaptive

cruise control, and route planning to avoid traffic. Fisker offers the Karma with a glass solar roof panel that is the largest automotive application of its kind. The solar panel will capture radiated power from the sun and convert it to stored electrical energy that will effectively increase the vehicle’s range. While adapting test procedures to account for the impact of this and other technologies would be prohibitively difficult, Fisker believes that it is in regulators’ interests to nevertheless encourage these technologies in the market. Fisker Automotive supports the approach of the U.S. Environmental Protection Agency’s May 7, 2010 ruling to establish greenhouse gas standards for light-duty vehicles. If the benefits are not captured by the EPA’s expanded five-cycle test procedures, EPA allows automakers to quantify the realworld impact of the technology by submitting its own testing methodology. If EPA approves, the benefit is reflected in that vehicle’s carbon dioxide contribution to the automaker’s fleet-wide carbon dioxide level. Fisker believes this approach accommodates and encourages a wide variety ofinnovative technologies that are needed to minimize fuel consumption and carbon dioxide emissions. New charging technologies • New charging methods increase convenience and speed • More accessible charging means more electrically powered miles The more accessible the charging infrastructure, the less the driver of extended range electric vehicles will depend on the range extender. Ease of use, charging efficiency, and reduced charging time all have major implications on how drivers use their vehicles and the extent to which these vehicles will have an impact. Fisker Automotive would like to draw attention to two charging infrastructure improvements in particular that regulatory bodies should anticipate: Level 3 charging and wireless charging. Level 3 Charging High-voltage, direct current (DC) charging, known as Level 3 charging, promises to significantly reduce vehicle charging time, but also carries with it serious safety requirements that call for a robust connector standard. However, the industry has yet to settle on a single Level 3 connector standard. While a number of Japanese companies have established the CHAdeMO standard, a revision to the Society of Automotive Engineers (SAE) standard J1772 to include level 3 charging as well as a revision to the International Electrotechnical Commission (IEC) 62196 standard favored

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by some German companies represent competing standards that create regulatory uncertainty. Wireless Charging Wireless vehicle charging could make electric vehicle charging significantly more convenient for consumers. This new approach to Electric Vehicle Supply Equipment (EVSE) would allow drivers to charge their vehicles by parking it in close proximity to an electric power source instead of physically plugging in a power cord. The technology SAE is currently working to establish a wireless charging standard in J2954 that would cover all three charging levels and set criteria for minimum performance and safety standards. Fisker Automotive is a member of the SAE committee working to establish this standard. A sufficiently accessible charging infrastructure would effectively eliminate the need for the range extender in a range extended electric vehicle for the vast majority of trips and significantly enhance the environmental benefits of these vehicles. Level 3 charging and wireless charging are important steps toward this goal. A sound regulatory structure that acknowledges these charging technologies would treat an extended range electric vehicle more like a battery powered electric vehicle than a hybrid vehicle. Internal Tests • Regulations limit the data automakers can communicate to customers • More data sharing is needed to help consumers build confidence in new technologies Communicating with customers is important for bringing new products to market, particularly when the technology involved is disruptive. Vehicle electrification presents new challenges to automakers in communicating the performance of its vehicles, owing in no small part to the use of old metrics (i.e. fuel consumption) in a context with which customers are not yet familiar (i.e. electricity consumption). Internal testing that goes beyond regulatory requirements could help prepare customers for what they can expect from their electric vehicle experience. However, automakers are legally limited in what they are able to claim about regulated vehicle performance metrics such as range and efficiency. As a result, Fisker Automotive will only communicate performance metrics that result from certification testing. However, we foresee at least two areas that could potentially benefit from internal testing and may be useful in assuaging consumer anxiety about the performance of electric vehicles: battery durability and the effect of varying conditions on vehicle performance. Battery Durability A commonly voiced concern with electric vehicles is the long-term degradation of the battery. While the battery is subject to minimum warranty requirements and in-use performance standards, an automaker may wish to conduct some internal stress-testing of the battery above and beyond the certification requirements. Such testing could be useful in ensuring customers that vehicle batteries are durable and robust and minimize the apparent risk they are taking on by purchasing an electric vehicle. Battery Performance Vehicle battery performance is affected by environmental conditions and by driver demands. As a technology that still represents a small part of the vehicle market, consumers at large may be unfamiliar with the range of performance they can expect from an electrically-driven car, such as

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driving range in extreme temperatures or with a high auxiliary load. Internal testing under a wide variety of conditions, perhaps to communicate an envelope of performance that drivers may encounter, could be useful to help consumers build confidence in their vehicle. Fisker believes that an easing of the restrictions regarding the types of performance metrics automakers may share with their customers is appropriate given the novelty of vehicle electrification and its great potential to reduce the environmental impact of vehicles. Along with a robust incentive environment to encourage the adoption of electric vehicles, properly communicating the advantages and capabilities of electric vehicles at the consumer level is important to their longterm success. Conclusion Fisker Automotive thanks the European Commission for inviting us to provide a response to this important study that will inform type approval test procedures for electric vehicles and hybrid electric vehicles. As a manufacturer of premium electric vehicles with extended range (EVer ™), we are committed to bringing uncompromised, responsible luxury to consumers in Europe and around the world. We are happy to provide the European Commission and other regulatory agencies any further comment or assistance.

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Fisker Automotive (Input as received from Fisker Automotive at the 27th of June 2011) Response to Stakeholder Input Request: European Commission on Type Approval Test Procedures for Electric Vehicles and Hybrid Electric Vehicles Fisker Automotive is pleased to have the opportunity to respond to the European Commission as it conducts a study to support the revision of specific type approval test procedures related to emissions and the environmental utility of electric vehicles and hybrid electric vehicles. Fisker Automotive is a privately owned auto manufacturer headquartered in Anaheim, California. Fisker Automotive builds environmentally conscious vehicles with passion, style and performance for the global market. Fisker’s first vehicle is Karma, an electric vehicle with extended range (EVer ™). Our manufacturing partner for the Fisker Karma is Valmet Automotive in Uusikaupunki, Finland. Valmet has a track record of producing high quality, premium automobiles, including manufacturing the Boxster for Porsche. Europe is an important market for Fisker, representing 40 percent of global sales. Fisker is appreciative of the opportunity to comment on this study and would like to remain engaged throughout this regulatory process and future policy-making activities. Introduction The comments presented here refer to a May 18, 2011 letter from the European Commission. The letter made two separate input requests. Fisker responded to the first input request on June 14, 2011, in a separate document. The current document will address the second request, which seeks input on the following topic: • Environmental utility parameters that could be standardized in type approval test

procedures – what type of information consumers would wish to have and how they expect to use this information.

Fisker Automotive addresses this topic in the full comments to follow. • Regarding vehicle test procedures: Fisker believes a data-based approach for estimating the

fraction miles driven on all electric range is needed and that there is potential for in-use data to play a role in vehicle certification

• Regarding the vehicle label: Fisker would like the label to continue to emphasize CO2 emissions, include comparisons of operating and CO2-based tax costs within the vehicle class, and include performance under various scenarios to show the range of expected performance

• Regarding the European Union’s approach to electric vehicles: Credits should be given for vehicles with significant all electric range, and some suggested changes to type approval procedures would help streamline the process

Test Procedures • The assumed 25 km distance between battery recharges is reasonable, but a variable

factor based on real-world data is preferred • In-use vehicle data could play an important role in supplementing certification data Weighting Factor for Electric Driving Presenting a single CO2 emissions rating for plug-in hybrid electric vehicles and electric vehicles with extended range represents a challenge for regulators. A common approach is to measure the

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CO2 emissions under charge depleting mode and the CO2 emissions under charge sustaining mode, then combine these two values into a single value with a weighting factor. United Nations Economic Commission for Europe (UNECE) Regulation No. 101, Annex 8, Section 3.4.2 defines the approach that the UNECE has taken. As shown below, this calculation assumes a 25 km driving distance between battery recharge events.

Figure 1: UNECE Regulation No. 101, Annex 8, Section 3.4.2

An alternative method employed by the U.S. Environmental Protection Agency uses a Utility Factor as defined by Society of Automotive Engineers (SAE) J2841 to weight the charge depleting and charge sustaining modes. The Utility Factor approach relies on driving statistics from the U.S. National Highway Transportation Survey to determine what fraction of driving would be performed in charge depleting mode for a given electric range. A comparison of the two approaches, as illustrated below, shows that the assumed 25 km between battery recharges in the UNECE method creates a reasonably close approximation of the Utility Factor curve. For example, a plug-in hybrid vehicle with a 60 km electric-only range would be assumed to drive purely electric about 60% of the time under the utility factor method and about 70% of the time under the UNECE method.

The weighted values of CO2 shall be calculated as below:

M = (De·M

1 + D

av·M

2)/(D

e + D

av)

Where: M = mass emission of CO2 in grams per kilometre M1 = mass emission of CO2 in grams per kilometre with a fully charged

electrical energy/power storage device M2 = mass emission of CO

2 in grams per kilometre with an electrical

energy/power storage device in minimum state of charge (maximum discharge of capacity)

De = vehicle’s electric range, according to the procedure described in Annex 9, where the manufacturer must provide the means for performing the measurement with the vehicle running in pure electric operating state.

Dav = 25 km (assumed average distance between two battery recharges)

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Figure 1 Comparison of Utility Factor and UNECE Weighting Methods

Fisker Automotive is supportive of the UNECE approach, given the relative agreement between the two methods, and recognizes that it is a reasonable intermediate solution. Nevertheless, the 25 km Dav factor is somewhat arbitrary and little information is given to motivate the selection of this value. Moving forward, the Dav factor could be treated as a variable that could be updated periodically to reflect real driving behavior. Collecting real-world driving behavior data would better inform the value of this factor. Utilizing Driving Data Looking ahead, Fisker believes that regulators should consider moving toward real-world, in-use vehicle data as the basis for certification. Regulators could collect data from a statistically significant sample of drivers using data loggers and GPS. This data could then be mapped to speed/load data points gathered from a test procedure that fully characterizes a vehicle’s performance capabilities. The resulting performance metrics would be more representative of realworld performance than drive cycles that attempt to imitate average driver behavior. Additionally, Fisker believes that driver behavior data gathered and submitted by automakers could play a role in the vehicle performance metrics communicated to consumers. While such a proposition would have been infeasible in the past, technology has made the barrier for automakers to collect robust, statistically significant in-use vehicle data increasingly low. Regulators could establish a mechanism to account for this in-use vehicle data, such that adjustments could be made to compensate for discrepancies between test procedure-based performance estimates and in-use data. Vehicle Label • Label should continue to emphasis CO2 emissions • Operating and effective costs, particularly taxes and other CO2-based fees, should be

presented on the label if presented as comparisons to other vehicles within the vehicle class

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• Scenario-based performance estimates should also be provided to show range of expected performance

Directive 1999/94/EC, Annex I describes the information that vehicle labels must include at a minimum. The only two metrics included in the requirements are official fuel consumption and specific emissions of CO2. Fisker Automotive supports the mandatory inclusion of these two metrics. Fuel consumption and CO2 emissions are well known to the public in Europe. As consumptive metrics, they allow quick comparisons between different vehicles to judge fuel savings. In contrast, fuel economy (miles per gallon) can be deceptive in judging the incremental differences in fuel savings represented by different fuel economy numbers, and should be left off of European labels. While not strictly technology neutral given their relevance to petroleum-based liquid fuels, a label that consistently applies fuel consumption and CO2 metrics to all technologies will create a consistent basis for comparison. Fisker Automotive recommends including additional standardized information on the label that will allow potential buyers to make more informed decisions. An example of a vehicle label from Ireland, below, includes much of the additional information that Fisker recommends. Figure 2 CO2 Comparison within Vehicle Class

An emphasis on CO2 emissions is appropriate for consumers to make quick comparisons between vehicle models. The color bands and letter grades they scale with a particular country’s CO tax structure changes. Fisker also recommends a comparison within the vehicle’s class, such as a range of CO2 ratings for vehicles within that class. This way, consumers may more readily compare a particular vehicle with its direct competitors Segments, by weight, or by a combination of exterior dimensions, such as vehicle footprint. In-Class Comparison of Operating and Tax Costs Additional costs, such as acquisition tax and operating costs, are another important factor for consumers to take into consideration. This information could be included on the label as well, if

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placed in the proper context of making comparisons within a vehicle class. Operating costs could be calculated for consumers on the label directly, with clearly stated assumptions, but only if presented along with costs for typical vehicles in the same class. For instance, annual fuel cost could be presented in terms of fuel cost savings over five years as compared to the typical five year fuel cost for other vehicles in the class. Additionally, CO2-based taxes for a particular country could be stated here, including any acquisition tax or VAT that may depend on CO2, bonus-malus awards or penalties based on CO2, and motoring or road taxes that are CO2-based. Again, placing these numbers within the context of the vehicle’s class is crucial. The effective tax rate by itself is not particularly meaningful if it is not compared against similar vehicles. The differential in effective cost between low-CO2 and high-CO2 vehicles within a particular class is often large and appropriately illustrates the benefits of electric vehicles. This is an important purchase factor that should be clearly communicated to consumers. Performance Estimates under Different Scenarios Finally, a section that provides CO2 emissions and/or fuel consumption under different driving scenarios would be helpful for consumers to gauge the performance they might expect from their own driving behavior. Driver behavior is a larger factor in the performance of plug-in hybrid electric vehicles than other vehicle types because ultimately the fraction of the time spent driving on electricity will depend on the driver’s decisions. In a plug-in hybrid electric vehicle, a driver’s charging habits and trip length will make the difference between consuming some fuel and consuming zero fuel. For these reasons, the vehicle label should provide information on vehicle performance assuming a range of trip lengths and distances between recharge events. Fisker Automotive believes that drivers of our vehicles will tend to take advantage of the electric range of our vehicles, and recharge them more frequently than is generally assumed by regulators. Plug-in hybrids, particularly Fisker’s electric vehicle with extended range (EVer™), are a new type of vehicle and it is largely unknown how drivers will actually use them. As automakers learn more about how their customers use these vehicles through acquisition of in-use data, for instance, Fisker believes it will be important to communicate the real-world performance to potential customers on the vehicle label. Fisker would like regulators to consider the allowance of a section on the vehicle label for in-use vehicle performance data that would supplement that certification performance data so that customers may make a more educated decision. European Union’s Regulatory Approach to Electric Vehicles • Credits should be given to vehicles with significant all electric range to encourage the

adoption of these vehicles in the market • A number of changes are needed to type approval test procedures to streamline the

process Vehicle electrification is a disruptive change for the automotive industry that offers a pathway to significantly reduced CO2 emissions and criteria pollutants and greater energy independence. As one of the few companies that has shouldered the considerable investment and risk to exclusively produce electrically-driven vehicles, Fisker believes that governments should utilize regulation to encourage the adoption of this new generation of vehicles. Toward this end, we offer for consideration a number of general comments regarding the European Union’s regulatory approach to electric vehicles.

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CO2 Standards • Continue to assign 0 g/km CO2 emissions for the grid electricity that electric vehicles use for

propulsion. • Provide credit for technologies with CO2-reducing benefits that are not properly accounted

for in the vehicle test procedures, including technologies such as solar panels and driver feedback systems to encourage more efficient driving. This is another opportunity to utilize in-use data collected by automakers to represent real-world benefits.

• Reconsider allowing vehicles to participate in the EU Emissions Trading Scheme (EMS). A carbon credit market is a potential source of significant revenue for automakers with electrified vehicle fleets, thus providing an incentive for more automakers to introduce electric vehicles.

• Offer CO2 emission credits for vehicles with an all electric range greater than or equal to some minimum, such as 20 miles (32 kilometers).

• Offer criteria pollutant credits for vehicles with an all electric range to account for the fraction of driving in which the on-board engine will be shut off.

Type Approval Regulations • Include all EV/HEV type approval requirements in a single document. A multitude of

directives and regulations (EC 715, EC 692, UNECE 83, UNECE 101, and numerous annexes) must currently be referenced for type approval.

• Harmonize European On-Board Diagnostic (EOBD) requirements with California Air Resources Board (CARB) OBD standards.

• Harmonize the all electric range determination with CARB procedures. • Harmonize test fuel specifications with EPA or CARB. • Provide less stringent emission deterioration factors (DF) for manufacturers of serieshybrid

vehicles. • Exclude the charge depleting test requirements for hybrid electric vehicles with an all

electric range greater than or equal to 20 miles (32 kilometers). • Introduce new engine power type approval regulations for series-hybrid vehicles. Conclusion Fisker Automotive thanks the European Commission for inviting us to provide a response to this important study that will inform type approval test procedures for electric vehicles and hybrid electric vehicles. As a manufacturer of premium electric vehicles with extended range (EVer ™), we are committed to bringing uncompromised, responsible luxury to consumers in Europe and around the world. We are happy to provide the European Commission and other regulatory agencies any further comment or assistance.

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FEMA (Input as received from FEMA) Dear Mr. Kok, It would be in the interest of users of electric powered two wheelers to be able to rely on the manufacturers’ information regarding vehicle range. As user’s experience as well as tests have shown many vehicles are unable to reach the range promised by manufacturers. FEMA suggests a simple test cycle that should be offered by the Commission to manufacturers in order to calculate the maximum range of a vehicle. Since there are many SME’s among the manufacturers of two wheeled EVs and HEVs the suggested test cycle should be easy to duplicate and rather cheap in its application. In the long run also the durability of batteries should be tested and the information should be made available to consumers. Kind regards,

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Going Electric (Input as received from Going Electric) Response to Stakeholder Input Request: European Commission on Type Approval Test Procedures for Electric Vehicles and Hybrid Electric Vehicles Going-Electric is pleased to have the opportunity to respond to the European Commission as it conducts a study to support the revision of specific type approval test procedures related to emissions and the environmental utility of electric vehicles and hybrid electric vehicles. Going-Electric, the Association for Electric Vehicles and their users in Europe, is a non-profit association (AISBL) under the Belgian law, based in Brussels. Our members are businesses, associations and NGOs, as well as individuals, promoting Electric Vehicles (EVs) in Europe as the most sustainable motorised road vehicles. We promote all types of electrically powered vehicles in the European Union: cars, trucks, buses, motorcycles and bicycles, whether Battery Electric Vehicles, Extended Range Electric Vehicles or Fuel Cell Vehicles. Going-Electric is the only organization whose mission is "to be the voice of all EV stakeholders and work towards a European legal framework enabling a European leadership in EV production and commercialisation". Introduction The comments presented here refer to a May 18, 2011 letter from the European Commission. The current document will address the first request, which seeks input on two topics summarized below: 1) Potentially important technological developments (e.g. special types of hybrids) and other considerations, which should be considered when revising and complementing EV/HEV test procedures. 2) EV/HEV related tests procedures, e.g. related to durability or battery parameters, industry applies on a non-regulatory basis for customer information and which could be a basis for respective harmonized test procedures at type approval. Going-Electric addresses these two topics in the full comments to follow. On the first topic, Going-Electric believes there are two major areas of important technological developments that should be considered when revising test procedures: • Proliferation of electrified powertrain configurations • Supplementary new technologies not be captured by traditional drive cycles On the second topic, we suggest two areas where internal testing may be useful and that could be used to inform type approval test procedures. Technological Developments Proliferation of electrified powertrain configurations • Extended range electric vehicle (EREV)

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• Regulations must accommodate growing complexity of powertrain configurations The automotive industry is currently experiencing a proliferation of powertrain configurations with varying levels of electrification – a trend that Going-Electric anticipates will continue in the future. While the extreme ends of the spectrum are well defined – zero electrification in conventional vehicles on one end and full electrification in purely battery-driven vehicles on the other – the range in between is becoming increasingly complex. Future regulatory decisions must be able to accommodate this complexity. Consumers and regulators have struggled with how to categorize these electrified powertrains. One early classification system widely used in the public sphere distinguished between “mild” hybrid systems that were only capable of assisting the internal combustion engine and “full” hybrid systems that could propel the vehicle on electricity alone for certain periods of time. The advent of start-stop systems and series-type hybrid electric vehicles revealed this classification to be overly simplistic. Likewise, defining hybrid electric vehicles (HEVs) and plug-in hybrid electric vehicles (PHEVs) based only on whether they are capable of accepting electricity from external sources is problematic in that it does not account for fundamental differences in powertrain configurations. Even a distinction between parallel or series hybrid drive is not straightforward. A number of current hybrid models blend series and parallel operation depending on driving conditions. In contrast, a new type of powertrain in the hybrid range exists: Extended Range Electric Vehicles (EREV) such as Chevrolet Volt, Opel Ampera or Fisker Karma. At no time does the engine ever directly power the wheels. This new powertrain type is not adequately accounted for in test procedure regulations. United Nations Economic Commission for Europe (UNECE) Regulation 83, Annex 14, categorizes hybrid electric vehicles along two parameters: 1) whether the vehicle is Off-Vehicle Charging (OVC) capable or Not Off-Vehicle Charging (NOVC) capable, and 2) whether the vehicle is with or without an operating mode switch. The same categorization is also used in UNECE Regulation 101, Annex 8. This regulation classifies EREV, true series hybrids, in the same category as parallel/series hybrids even though these vehicles could behave very differently in the real world. Additionally, the operating mode switch category is not clearly defined nor does it account for the various levels of driver control offered by different vehicles. Some vehicles may offer a certain level of control, such as the ability to choose the level of regenerative braking, but may force the driver to deplete the vehicle’s electric range before switching to a blended driving mode. Some PHEV or EREV allow the driver to have a large degree of control over the vehicle’s operating mode. For example in the Fisker Kama, the range-extending engine generates electricity in the Karma’s “Sport” mode and does not operate at all in full EV mode. Furthermore, the driver’s ability to select either mode at will allows the driver to better manage the battery’s electricity capacity to suit his or her needs. For instance, if a driver is travelling from a suburb into a dense city with a congestion charge, he or she may choose to save the full EV mode capability until arriving at the city center. Vehicle test procedures should not assume this same level of control in other plug-in hybrid electric vehicles.

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Technologies not captured by test cycles • Low-power horn for EVs • Supplementary technologies offer real world benefits • Regulation should offer some credit to encourage such technologies Under increasing pressure to reduce fuel consumption and carbon dioxide emissions, automakers may turn to technologies that provide benefits that may not be reflected in current vehicle test procedures. Examples of such technologies include: • active aerodynamics • variety of intelligent systems such as regenerative breaking, efficiency-improving driver

feedback, adaptive cruise control, and route planning to avoid traffic. All vehicles are dangerous while moving backwards, but EVs are maybe even more dangerous in certain situations such as parking exits, due to their noise- and pollution-free advantages. Therefore, Going-Electric recommends that EVs should have a second, low-power, horn, that EV drivers could use wisely to indicate their proximity to pedestrian/cyclists and other weak road users, without scaring them which is the actual result if using the horn already existing on every car. Going-Electric supports the approach of the U.S. Environmental Protection Agency’s May 7, 2010 ruling to establish greenhouse gas standards for light-duty vehicles. If the benefits are not captured by the EPA’s expanded five-cycle test procedures, EPA allows automakers to quantify the real world impact of the technology by submitting its own testing methodology. If EPA approves, the benefit is reflected in that vehicle’s carbon dioxide contribution to the automaker’s fleet-wide carbon dioxide level. Fisker believes this approach accommodates and encourages a wide variety of innovative technologies that are needed to minimize fuel consumption and carbon dioxide emissions. Internal Tests • Regulations limit the data automakers can communicate to customers • More data sharing is needed to help consumers build confidence in new technologies Communicating with customers is important for bringing new products to market, particularly when the technology involved is disruptive. Vehicle electrification presents new challenges to automakers in communicating the performance of its vehicles, owing in no small part to the use of old metrics (i.e. fuel consumption) in a context with which customers are not yet familiar (i.e. electricity consumption). Internal testing that goes beyond regulatory requirements could help prepare customers for what they can expect from their electric vehicle experience. Going-Electric foresee at least two areas that could potentially benefit from internal testing and may be useful in assuaging consumer anxiety about the performance of electric vehicles: battery durability and the effect of varying conditions on vehicle performance. Battery Durability A commonly voiced concern with electric vehicles is the long-term degradation of the battery. While the battery is subject to minimum warranty requirements and in-use performance standards, an automaker may wish to conduct some internal stress-testing of the battery above and beyond the certification requirements. Such testing could be useful in ensuring customers that vehicle batteries are durable and robust and minimize the apparent risk they are taking on by purchasing an electric vehicle. Battery Performance

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Vehicle battery performance is affected by environmental conditions and by driver demands. As a technology that still represents a small part of the vehicle market, consumers at large may be unfamiliar with the range of performance they can expect from an electrically-driven car, such as driving range in extreme temperatures or with a high auxiliary load. Internal testing under a wide variety of conditions, perhaps to communicate an envelope of performance that drivers may encounter, could be useful to help consumers build confidence in their vehicle. Going-Electric believes that an easing of the restrictions regarding the types of performance metrics automakers may share with their customers is appropriate given the novelty of vehicle electrification and its great potential to reduce the environmental impact of vehicles. Along with robust incentive environment to encourage the adoption of electric vehicles, properly communicating the advantages and capabilities of electric vehicles at the consumer level is important to their long-term success. Conclusion Going-Electric thanks the European Commission for inviting us to provide a response to this important study that will inform type approval test procedures for electric vehicles and hybrid electric vehicles. We are happy to provide the European Commission and other regulatory agencies any further comment or assistance.

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Honda Motors Europe (An interview by phone was kept with Honda Motors Europe. Form this interview no report was made. Please find below the answers of Honda from a few additional questions) From: honda-eu.com To: <[email protected]> Date: 15-9-2011 13:31 Subject: DG Enterprise & Industry - Test procedures hybrid electric vehicles - additional Honda answers to outstanding questions Beste heer Kok, Hierbij onze antwoorden op de nog openstaande vragen die U ons stelde tijdens het telefonisch onderhoud op 12 augustus. Laat ons gerust weten als er nog bijkomende vragen zouden zijn. Mvg Honda Motor Europe Ltd - Aalst Office Wijngaardveld 1 B-9300 AALST BELGIUM T +32 (0)53 725352 F +32 (0)53 725350 Mobile +32 (0)477 313163 [email protected] Q: Is the draft ISO 13064-1 used to determine the range for the EV Neo? A: No. The reason is that ISO13064-1 was not published at the time of EV Neo development. The procedure that was used is contained in the Japanese TRIAS (test procedures for new-type vehicles) 99-013-01 "Running distance by one charge and A/C power consumption - test procedures (Electric motorcycle travelling at constant speed)". TRIAS can be considered as being practically equivalent to ISO13064-1 ANNEX 3. Q: Regarding EV battery lifetime, how is it determined? Is there a standard? A: Currently there's no established harmonised test procedure, so it is determined by a Honda in-house test procedure. Life time/number of charge cycles are not officially announced. Q: Would Honda like to have this standardised? A: Honda feels the necessity for such standard and is participating in discussions inside JAMA (for both motorcycle and car). Additionally, there is a plan to start standardization activity at ISO level for Li-ion batteries for motorcycles/mopeds.

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PIAGGIO (Input as received from PIAGGIO) • Environmental utility parameters which are already regulated Parameters such as: Polluting emissions, Noise, Max Power and Max torque through self declaration, Mass of battery excluded from the unladen vehicle mass, EMC . • Environmental utility parameters which should be regulated by means of standardised test

procedures Parameters such as: Specific telltales, Measurement of max power and max torque, Energy from regenerating braking, Range in pure electric, Electrical functional safety both for battery charger and for the vehicle. • Reasons for whether or not to be in favour of standardised procedures For the measurement of some parameters it would be appropriate the use of standardised procedures, which should not be binding for type-approval process, in order to give customers parameters on which making their best choice. • Environmental utility parameters that provide key information to consumers when purchasing a

Category L EV/HEV For instance CO2 emissions for Hybrids, energy consumption, maximum speed, accelerations, climbing capability and battery charging time.

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PON (No report was made of the interview wqith PON, one of the largest car importers in The Netherlands. However, a few notes were taken into account in the 2011 report)

PON indicates that most safety aspects, including the safety of electric systems, are already addressed in existing standards and certification.

PON considers it to be important for the EU to provide common and harmonized rules/methodology for countries to calculate WTW emissions. Another suggestion by PON concerns the environmental impact of production and decommissioning of vehicles. Consumers may also want to know the environmental impact or CO2 emissions from production and

PON highlights that batteries of EVs are currently about 1/3 of the total value of an EV

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SMMT – OEM (Input as received from SMMT) From: @smmt.co.uk Sent: 17 June 2011 17:28 To: Barlow, Tim J Subject: RE: Commission study on consumer information for EVs/HEVs Hi Tim Please see some quick feedback from one OEM below We need to consider if the best way for OEMs to input is face to face and if we can set that up Best regards Information that could be collected during T/A: • We believe that T/A testing needs to be completely separate from the process of

gathering data in support of this study . • Type Approval testing normally takes place at the most critical part of the development

process which is just prior to start of production and sales launch. Any additional collection of data or supplementary test work during this period may have an impact on timing and thus has the potential to delay planned SOP and/or sales. So it is imperative that the technical service focuses on the manufacturer’s priority of certifying its product for market.

• Whilst we have no issue with the technical services passing on validated type approval data obtained during the test, any additional non t/a data is confidential to the vehicle manufacturer. Parameters such as ‘real use’ range and battery life may be commercially sensitive so needs to be discussed case by case with the individual company.

Provision of data and information gathered during vehicle development testing • This should be left to the individual manufacturer to decide if they wish to either

provide existing data gathered during the normal development process, or even carry out separate test activity in support of this study. A vehicle manufacturer will need to consider the pros and cons in more detail before deciding if it has the necessary resource or capability to participate.

Information that could be useful for the buyer: • Battery(vehicle) Range: There is already a study underway in the GRPE informal

group reviewing ‘real world’ drive cycles for all kinds of power trains including EVs and HEVs under WLTP-DHC. It is hoped that the Commission study will feed into this and not confuse matters by creating a separate work stream. Consumers will be confused if manufacturers are obliged to declare a range value in addition to the legally required R101 figure.

• Energy Consumption: As with range this needs to be dealt with thro the auspices of WP29 GRPE because again this is a parameter which is measured under type approval within ECE R101. What is clearly of use to the consumer is the cost of energy which can vary significantly between EU markets and energy providers and it

is for utility companies to establish tariffs that encourage the uptake of EVs and PHEVs.

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• Cruising speed: This is a vehicle performance parameter which should be determined by customer demand and market forces not legislation. Why should EVs power train be any different to others? Ultimately the consumer will decide and the only way to attract them to EV products is for VMs to develop performance parameters which meet the customer needs.

• Battery life: Battery technology is currently developing at a rapid rate and we would agree that there is a need for the relevant standards and norms to keep pace. However, each individual manufacturer will want to include battery life within its own warranty policy which needs to be competitive on the market place or the customer will turn away. So again, we see no need to legislate this parameter.

• Equivalent CO2 - would have to use an agreed energy mix, problem will be changes in this value over time (and that this value would be ‘~ well to wheel’ rather than ‘tank to wheel’ as published for ICE vehicles…)

• Cost per km – again would need an agreed energy cost (however this is done already in the US for label figures)

Public Policy And Vehicle Legislation Department The Society of Motor Manufacturers and Traders Limited Tel: +44 (0)20 7344 1624 Mob: +44 (0)7732 609828 Fax: +44 (0)20 7973 0529 Web: www.smmt.co.uk

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