Presentation to the RDE LDV working group on RDE th March 2017

Transcription

1 Presentation to the RDE LDV working group on RDE 4 by OECVA 10 th March 2017

2 The WAV Market Europe has an ageing population. We are living longer, but enduring a greater number of years in poor health and with reduced mobility. Whilst improvements are being made in the accessibility of public transport, people are coming to expect a level of personal mobility, and the dignity & choice that goes with it.

3 EU WAV Production Total annual production of WAVs across EU estimated at 12,000. Around 60 companies across the EU convert vehicles into WAVs. The UK, Germany, the Netherlands France and Italy are the main WAV manufacturing countries in the EU. Most converters produce less than 1000 cars per type, per year. Article 22 of Directive 2007/46/EC prohibits Special Purpose Vehicles from using the ECSSTA scheme.

4 Basic design of a typical WAV Most WAVs start life as small or medium cars or vans. The conversion comprises lowering the floor to: A) Maximise headroom B) Provide safer, shallow access C) Improve forward vision for the wheelchair user D) Improve comfort with a lower centre of gravity

5 Constraints in the base vehicle from an emissions perspective The WAV converter has no control over: Tyres and other common sources of rolling resistance The mapping of the engine management system Fitting of energy saving features such as stop start, or smart charge alternators. The choice of High and Low test mass of the base vehicle. Base vehicle manufacturers sometimes also impose additional conditions (separate to type approval legislation) on converters before they agree to support the modified vehicle under warranty.

6 Conflict for Space

7 Conversion factors affecting emissions 1. Exhaust modifications The lowered floor under the back of a typical WAV usually necessitates a revised exhaust system design. We have to preserve the emissions control equipment in the exhaust (e.g. catalyst(s), particulate filter, EGR valves and SCR catalysts), but we modify the exhaust downstream of these. We try to maintain back pressure within base vehicle prescribed limits.

8 Conversion factors affecting emissions 1. Exhaust modifications (continued) Directive 2007/46/EC Annex XI Appendix 3 Note W1, appears against the entry for Emissions: W1 Requirements shall be complied with, but modification in the exhaust system is permitted without any further test provided the emission control devices including particulate filters (if any) are not affected. No new evaporative test shall be required on the modified vehicle on condition that the evaporative control devices are kept as fitted by the manufacturer of the base vehicle. An EC type approval issued to the most representative base vehicle remains valid irrespective of change in the reference mass.

9 Conversion factors affecting emissions 2. Changes to mass By the time a fabricated lowered floor section and ramp are fitted, plus wheelchair tie down equipment and any specialist seating, most WAVs usually weigh between 50kg and 200kg more than the base vehicle. However, some conversions fitted with tail lifts can be more than 300kg heavier than the base vehicle. This is why it was necessary to introduce the last sentence of Note W1 in Annex XI, Appendix 3, of 2007/46/EC. Few (if any) WAV converters increase the maximum permitted mass of the vehicle.

10 Conversion factors affecting emissions 3. Changes to aerodynamics A low floor conversion is likely to add a small amount of underbody drag to the vehicle as a whole. Some WAVs are used as wheelchair accessible taxis, so the addition of a taxi sign on the roof also adds a small amount of drag. Other accessibility aids to assist persons of reduced mobility other than wheelchair users (such as side steps) have a similar effect.

11 Perceived challenges Ideally, we need the WLTP CO2 calculation tool made available by the manufacturer of the base vehicle to cover a broad enough range of masses and aerodynamic changes to allow WAV conversions to be included. We need to be confident that a subsequent RDE test on a converted WAV will not put one or more of the regulated pollutants outside the permitted conformity factor for the Stage 1 vehicle. (This being especially important in later RDE packages as the conformity factors are reduced). The industry has worked hard to ensure that WAVs can be type approved, as this is preferable to post registration conversion and we need flexibility to allow us to continue to produce vehicles that meet the needs of the disabled user.

12 Overall Impact WAVs only make up a tiny proportion of road vehicles. Annual mileage of an average WAV in the UK is 5 7,000 miles a year. We do not believe WAVs will add a measurable contribution to overall pollution. The effect of the changes to the vehicle is not expected to have a significant effect on either CO2 or regulated pollutants from the vehicle parc. The WAV market is acutely price sensitive as many WAV users do not have access to substantial funds. We need to do everything possible to minimise the cost of these vehicles and any avoidable administrative burden would help this. We believe that the gains that could be made in reduction of emissions in this sector, would be disproportionate to the effect it would have on the industry.

13 The alternative to low floor WAVs Low floors give extra headroom for the disabled person in their wheelchair Low floors make getting in & out much easier and safer Low floors mean a smaller, more socially acceptable and environmentally friendly vehicles can be used rather than larger, heavier minibus type vehicles with bigger engines and higher emissions.

14 Summary A WAV is critical to the normal everyday lives of those who use them. A WAV is a needs driven purchase and is costsensitive. Any further regulatory burden will increase cost to the end user. WAV users choose small WAVs (M1) because they enjoy lower fuel costs, ease of parking and they look the same as any other car on the road.

15 OECVA Organisation Europeenne des Constructeurs de Vehicules Accessibles (OECVA) is a Trade Association for European manufacturers of wheelchair accessible vehicles It has 18 affiliated member companies based in the UK and WAV manufacturing companies in Czech Republic, France, Germany, Netherlands, Spain and Italy. As the WAV market develops to meet the needs of disabled people throughout Europe it is expected that more MS will become involved.

16 Ian Hopley Technical Consultant