Verband der TÜV e.v.

Transcription

1 Verband der TÜV e.v. Contribution on RDE Data Evaluation Method Details from the VdTÜV German Digital RDE Round Robin Project - Amendments RDE Package 3 and 4 - Presented at the RDE Package 4 Meeting Bruxelles, 12th and 13th December 2017

2 VdTÜV German Digital RDE Round Robin Project Based on the VdTÜV experience with real round robin chassis dyno emission testing, VdTÜV created the platform for the RDE Digital Round Robin. In 2017 based on an EURO 5 Diesel RDE Dataset from TAA of Germany, KBA, a first round robin for RDE Package 1+2 was performed. Round Robin for RDE Package 3 ongoing. The need of exchange of experts has become more necessary in the light of rapid changes and in the need of establishing a quality and more robust RDE process. Results show a variation in NOx emission for RDE Package 1+2 of EMROAD Appendix 5 NOx: around 11% for city and total result Clear Appendix 6 NOx : around 11% for total result and 18% for city result In the view of RDE4 changes to the appendix 5 and appendix 6 calculations, we focus on more basic parameters, that will be applicable to the final RDE4 data evaluation method Verband der TÜV e.v. Karsten Mathies / VdTÜV 2 Brüssel 12./

3 Participants * AUDI AG, Honda R&D Europe GmbH, ISUZU, Mitsubishi Motor, Porsche, Volkswagen Bosch Engineering GmbH * DEKRA, FAKT GmbH, TÜV Hessen, TÜV Nord, TÜV Rheinland * PEMS Manufacturer: AVL, Horiba, Maha, Sensors Verband der TÜV e.v. Karsten Mathies / VdTÜV 3 Brüssel 12./

4 Amendments RDE Package 3 & 4 Round Robin RDE 2017 VdTÜV - Verband der TÜV e.v. Association of TUVs Friedrichstraße 136 D Berlin 4, rue Jacques de Lalaing B-1040 Bruxelles T.: (Berlin) T.: (Bruxelles) 1

5 Reg.: Reg.: Appendix 7c Appendix 7c Topic: VERIFICATION OF TRIP CONDITIONS Topic: VERIFICATION OF TRIP CONDITIONS 4. VERIFICATION OF TRIP CONDITIONS It shall be verified in a simple three-step procedure that: (1) the trip complies with the general requirements, boundary conditions, trip and operational requirements, and the specifications for lubricating oil, fuel and reagents defined in points 4 to 8 of this Annex IIIa; (2) the trip complies with the trip conditions defined in Appendices 7a and 7b of this Annex IIIa. (3) the combustion engine has been working for a minimum cumulative distance of 12 km under urban conditions. If the at least one of the requirements is not fulfilled, the trip shall be declared invalid and repeated until the trip conditions are valid. 4. VERIFICATION OF TRIP CONDITIONS It shall be verified in a simple three-step procedure that: (1) the trip complies with the general requirements, boundary conditions, trip and operational requirements, and the specifications for lubricating oil, fuel and reagents defined in points 4 to 8 of this Annex IIIa; (2) the trip complies with the trip conditions defined in Appendices 7a and 7b of this Annex IIIa. (3) the combustion engine has been working for a minimum cumulative distance of 12 km under urban conditions over the whole RDE test. If the at least one of the requirements is not fulfilled, the trip shall be declared invalid and repeated until the trip conditions are valid. Reasoning: The meaning of under urban conditions is not clear defined. Is it only the first part of the test or all urban events all over the whole RDE test. In our eyes the whole RDE test make more sence. 2

6 RDE Package 3 ( ) Proposed amendments to RDE Package 3 ( ) Annex IIIA Annex IIIA 4. GENERAL REQUIRMENTS 4. GENERAL REQUIRMENTS 4.5. In order to also assess emissions during trips in hot start, a certain number of vehicles per PEMS test family, specified in point in Appendix 7, shall be tested without conditioning the vehicle as described in point 5.3, but with a warm engine In order to also assess emissions during trips in hot start, a certain number of vehicles per PEMS test family, specified in point in Appendix 7, shall be tested without conditioning the vehicle as described in point 5.3, but with a warm engine. Warm engine is coolant start temperature from 70 C or higher. Reasoning: Warm engine is not defined in this case. Is a warm engine every RDE test without conditioning the vehicle as described in point 5.3 or after 5 min driving before the RDE test start or a RDE test with a coolant start temperature from 30 C or 50 C? Everything is possible. 3

7 RDE Package 3 ( ) Proposed amendments to RDE Package 3 ( ) ANNEX IIIA VERIFYING REAL DRIVING EMISSIONS ANNEX IIIA VERIFYING REAL DRIVING EMISSIONS 5. BOUNDARY CONDITIONS Topic: Ki-Factor 5. BOUNDARY CONDITIONS Topic: Ki-Factor 5.5. Vehicle condition and operation 5.5. Vehicle condition and operation All results will be corrected with the Ki factors or with the Ki offsets All final emission results (App or App or App.7c 5., developed by the procedures in subannex 6 of Annex XXI for typeapproval of a vehicle type with a periodically regenerating system manufacture choice of the Ki factors or with the Ki offsets developed depending on which method is relevant) will be corrected with the by the procedures in subannex 6 of Annex XXI of 2017/1151 for typeapproval of a vehicle type with a periodically regenerating system Reasoning: All results is not detailed enough. Apply on final emission results is more detailed. 4

8 RDE Package 3 ( ) Proposed amendments to RDE Package 3 ( ) ANNEX IIIA VERIFYING REAL DRIVING EMISSIONS ANNEX IIIA VERIFYING REAL DRIVING EMISSIONS 6. TRIP REQUIREMENTS / 7. OPERATIONAL REQUIREMENTS 6. TRIP REQUIREMENTS / 7. OPERATIONAL REQUIREMENTS 6. TRIP REQUIREMENTS 6. TRIP REQUIREMENTS The average speed (including stops) during cold start period as defined The average speed (including stops) during cold start period of the in Appendix 4, point 4 shall be between 15 and 40 km/h. The combustion engine (applies not for (P)-HEV) as defined in Appendix 4, maximum speed during the cold start period shall not exceed 60 point 4 shall be between 15 and 40 km/h. The maximum speed during km/h. the cold start period shall not exceed 60 km/h. 7. OPERATIONAL REQUIREMENTS 7.6. The idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s. The vehicle stop during the entire cold start period, as defined in point 4 of Appendix 4, shall be kept to the minimum possible and it shall not exceed 90 s. If the engine stalls during the test, it may be restarted, but the sampling shall not be interrupted. 7. OPERATIONAL REQUIREMENTS 7.6. The idling immediately after the first ignition of the combustion engine (applies not for (P)-HEV) shall be kept to the minimum possible and it shall not exceed 15 s. The vehicle stop during the entire cold start period, as defined in point 4 of Appendix 4, shall be kept to the minimum possible and it shall not exceed 90 s. If the engine stalls during the test, it may be restarted, but the sampling shall not be interrupted. Reasoning: It is not plausible to use the same cold start criteria for (P)-HEV and combustion engine vehicles. Cold start criteria for (P)-HEVs should be new defined (e.g. 15 sec criteria and 90 sec criteria - resting on a traffic light for more than 15 sec after the combustion engine turned on during resting) 5

9 RDE Package 3 ( ) Proposed amendments to RDE Package 3 ( ) Reg.: : Annex IIIA, Appendix 5 Reg.: : Annex IIIA, Appendix 5 Verification of trip dynamic conditions and calculation of the final RDE emissions result with method 1 (Moving Averaging Window) Verification of trip dynamic conditions and calculation of the final RDE emissions result with method 1 (Moving Averaging Window) 3.2. Calculation of window emissions and averages The following shall be calculated for each window determined in accordance with point 3.1., The distance-specific emissions M gas,d,j for all the pollutants specified in this annex; The distance-specific CO 2 emissions M CO2,d,j ; The average vehicle speed v j 3.2. Calculation of window emissions and averages The following shall be calculated for each window determined in accordance with point 3.1., The distance-specific emissions M gas,d,j for all the pollutants specified in this annex; The distance-specific CO 2 emissions M CO2,d,j ; The average vehicle speed v j In case a NOVC-HEV is tested, the window calculation shall start at the point of ignition on and include driving events during which no CO 2 is emitted. The first start of the first MAW window shall begin with the engine start, which is recognized as internal combustion engine speed n>50 rpm. In case a NOVC-HEV is tested, the window calculation shall start at the point of ignition on combustion engine on under consideration of the criteria n > 50 rpm and include driving events during which no CO 2 is emitted. Reasoning: Ignition on is not clear defined in this case. It does not make sense to start the window calculation when no combustion engine is running. Open question: weighting of windows when v < 1 km/h exclude the windows or set the emissions to zero. Is it plausible to add the v > 1 km/h criteria for the window start point for NOVC-HEV vehicles? 6

10 RDE package 4, , L 175/ , L 175/124 Proposed amendments to RDE package 4 Article 9 Article 9 4. The manufacturer and type approval authority shall not be obliged to carry out in-service conformity testing if the number of vehicles sold makes it difficult to obtain sufficient samples to test. Therefore, in-service conformity testing shall not be required if the annual sales of that ISC family, as defined in point 3 of Annex II to this Regulation, are less than across the Community. However, the manufacturer of such small series vehicles shall provide the approval authority with a report of any emissions related warranty and repair claims and OBD faults as set out in point 4.1 of Annex II to this Regulation. In addition, the type-approval authority and/or third parties may select such vehicle types to be tested in accordance to Annex II to this Regulation. 4. The manufacturer and type approval authority shall not be obliged to carry out in-service conformity testing if the number of vehicles sold makes it difficult to obtain sufficient samples to test. Therefore, in-service conformity testing shall not be required if the annual sales of that ISC family, as defined in point 3 of Annex II to this Regulation, are less than across the Community. However, the manufacturer of such small series vehicles shall provide the approval authority with a report of any emissions related warranty and repair claims and OBD faults as set out in point 4.1 of Annex II to this Regulation. In addition, the type-approval authority and/or third parties may select such vehicle types to be tested in accordance to Annex II to this Regulation. Vehicles as defined in 7.,8. and 9 of this article are not subjected to ISC testing, if the number of annually sold vehicles is less than across the community. 8. Wheelchair accessible vehicles, as defined in Appendix 3, of Annex XI, of Directive 2007/46/EC are exempt from the provisions of checking their in-service conformity. All other special purpose vehicles as defined in the same Annex XI, of Directive 2007/46/EC, shall be checked for in service conformity under the rules for multistage approvals described in Appendix 2 of Annex II to this Regulation. 8. Wheelchair accessible vehicles, as defined in Appendix 3, of Annex XI, of Directive 2007/46/EC are exempt from the provisions of checking their in-service conformity. All other special purpose vehicles as defined in the same Annex XI, of Directive 2007/46/EC, shall be checked for in service conformity under the rules for multistage approvals described in Appendix 2 of Annex II to this Regulation. 9. Vehicles according to point (3) b) of article 2 of regulation 2007/46/EC designed and constructed for use by the armed services, civil defense, fire services and forces responsible for maintaining public order shall be subjected to ISC only by the granting type 7

11 approval authority. Reasoning: Vehicles as defined in 7., 8. and 9 of this article are mostly produced by SME body-builders, the proposed ISC procedure produces a disproportional high burden for the manufacturers (determining road loads etc.). Due to the official duty of those vehicles only the granting type approval authority should be tasked with ISC. 8

12 RDE package 4, , L 175/ , L 175/124 Proposed amendments to RDE package 4 Annex II In-Service Conformity Annex II In-Service Conformity Appendix 2 ISC for vehicles with multi-stage approvals (MSV) and special Appendix 2 ISC for vehicles with multi-stage approvals (MSV) and special purpose vehicles (SPV) purpose vehicles (SPV) The OEM shall define the allowed values for the parameters listed in Armored vehicles, as defined in Appendix 2, of Annex XI, of Directive Table 2.b. If the final vehicle remains within these values for all 2007/46/EC shall be subjected to ISC only by the granting type parameters, then a second-stage manufacturer may be allowed to approval authority. use the original emission type approval. SPV according to Annex XI, Appendix 1 of Directive 2007/46/EC for M1 vehicles with a technical permissible maximum laden mass smaller or equal to 2500 kg shall follow the ISC procedure of this annex. SPV according to Annex XI, Appendix 1 of regulation 2007/46/EC for M1 vehicles with a technical permissible maximum laden mass larger 2500 kg a more detailed RDE process shall be developed. Until then, special provisions for ISC for those vehicles shall be agreed with the granting type approval authority. The OEM shall define the allowed values for the parameters listed in Table 2.b. If the final vehicle remains within these values for all parameters, then a second-stage manufacturer may be allowed to use the original emission type approval. Reasoning: (1) Due to the special provisions for type approval of those vehicles only the granting type approval authority should be tasked with ISC. (2) The TCMV Note on Special Purpose vehicles, published Brussels, 10 May 2017 clarifies the use of exemptions for SPV vehicles. For those vehicles, the base vehicle emission homologation is carried over without new testing, allowing the increase in reference weight. For vehicles with a technical permissible maximum laden mass larger 2500 kg, the WLTP family data does not apply any more. Table 2.b of this annex does not allow to determine the road load parameters of this vehicle. So, a more detailed procedure for those vehicles must be developed. The SPV with a technical permissible maximum laden mass smaller or equal to 2500 kg can follow all procedural RDE requirements. 9

13 RDE package 4, , L 175/ , L 175/124 Proposed amendments to RDE package 4 Appendix 1, Section 4.7, Topic: Speed signal, V2 Appendix 1, Section 4.7, Topic: Speed signal, V2 (a) a GPS; if vehicle speed is determined by a GPS, the total trip distance shall be checked against the measurements of another method according to point 7 of Appendix 4. (b) a sensor (e.g., optical or micro-wave sensor); if vehicle speed is determined by a sensor, the speed measurements shall comply with the requirements of point 8 of Appendix 2, or alternatively, the total trip distance determined by the sensor shall be compared with a reference distance obtained from a digital road network or topographic map. The total trip distance determined by the sensor shall deviate by no more than 4 % from the reference distance. (a) a GPS. If neither a validated ECU signal nor an additional sensor that fulfills the requirements of point 8 Appendix 2 is available, a GPS system (optional with dead reckoning ability) shall be used. If vehicle speed is determined by a GPS, the total trip distance shall be checked against the measurements of another method according to point 7 of Appendix 4 (b) a sensor (e.g., optical or micro-wave sensor); if vehicle speed is determined by a sensor, the speed measurements shall comply with the requirements of point 8 of Appendix 2, or alternatively, the total trip distance determined by the sensor shall be compared with a reference distance obtained from a digital road network or topographic map. The total trip distance determined by the sensor shall deviate by no more than 4 % from the reference distance If available an additional sensor (e.g., fifth wheel, optical or microwave sensor) can be used to determine vehicle speed. The speed measurements shall comply with the requirements of point 8 of Appendix 2. The sensor shall be calibrated to a traceable standard. (c) the ECU; if vehicle speed is determined by the ECU, the total trip distance shall be validated according to point 3 of Appendix 3 and the ECU speed signal adjusted, if necessary to fulfil the requirements of point 3.3 of Appendix 3. Alternatively, the total trip distance as determined by the ECU can be compared with a reference distance obtained from a digital road network or topographic map. The total trip distance determined by the ECU shall deviate by no more than 4 % from the reference. (c) the ECU; if vehicle speed is determined by the ECU, the respective signal shall be validated according to point 3 of Appendix 3 against a dyno calibrated to a traceable standard and if necessary the ECU speed signal shall be corrected by a linear fit to fulfil the requirements of point 3.3 of Appendix 3. The validated and if necessary corrected ECU signal shall be used to determine speed during the PEMS test. the total trip distance shall be validated according to point 3 of Appendix 3 and the ECU speed signal adjusted, if necessary to fulfil the requirements of point 3.3 of Appendix 3. Alternatively, the total trip 10

14 distance as determined by the ECU can be compared with a reference distance obtained from a digital road network or topographic map. The total trip distance determined by the ECU shall deviate by no more than 4 % from the reference. Reasoning: GPS is no reliable method for obtaining gap-less and accurate speed data (loss of satellite signals etc.). A correctly validated and corrected ECU signal should therefore be preferred. 11

15 RDE package 4, , L 175/ , L 175/124 Proposed amendments to RDE package 4 Appendix 4, Section 7 Appendix 4, Section 7 Topic: CONSISTENCY CHECK OF GPS VEHICLE SPEED Topic: CONSISTENCY CHECK OF GPS VEHICLE SPEED The vehicle speed as determined by the GPS shall be checked for consistency by calculating and comparing the total trip distance with reference measurements obtained from either a sensor, the validated ECU or, alternatively, from a digital road network or topographic map. It is mandatory to correct GPS data for obvious errors, e.g., by applying a dead reckoning sensor, prior to the consistency check. The original and uncorrected data file shall be retained and any corrected data shall be marked. The corrected data shall not exceed an uninterrupted time period of 120 s or a total of 300 s. The total trip distance as calculated from the corrected GPS data shall deviate by no more than 4 % from the reference. If the GPS data do not meet these requirements and no other reliable speed source is available, the test results shall be voided. The vehicle speed as determined by the GPS shall be checked for consistency by calculating and comparing the total trip distance with reference measurements obtained from either a sensor, the validated ECU or, alternatively, from a digital road network or topographic map. It is mandatory to correct GPS data for obvious errors, e.g., by applying the dead reckoning data a dead reckoning sensor or ECU vehicle speed data (if no dead reckoning sensor was present), prior to the consistency check. The original and uncorrected data file shall be retained and any corrected data shall be marked. The corrected data shall not exceed an uninterrupted time period of 120 s or a total of 300 s. The total trip distance as calculated from the corrected GPS data shall deviate by no more than 4 % from the reference. If the GPS data do not meet these requirements and no other reliable speed source is available, the test results shall be voided. Reasoning: The legislation currently only states that the GPS vehicle speed data shall be checked for consistency against a digital road network or topographic map, but neither does it specify how this shall be achieved nor does it define the requirements. A future version should define an algorithm or a scientifically precise description of the single steps, thus minimizing the chance of different results by different tool manufacturers. Furthermore, the requirements to the digital road network shall be specified, e.g. resolution and up-to-dateness. 12

16 RDE package 4, , L 175/ , L 175/124 Proposed amendments to RDE package 4 Appendix 5 Topic: CO2 Data source Appendix 5 Topic: CO2 Data source 4. Evaluation of windows 4. Evaluation of windows 4.1 Introduction 4.1 Introduction To obtain the distance-specific CO 2 emissions, the vehicle shall be To obtain the distance-specific CO 2 emissions over the Worldwide tested on the chassis dynamometer by applying the vehicle road load harmonized Light vehicles Test Cycle (WLTC) for RDE type approvals, settings as determined following the procedure prescribed in Annex 4 the vehicle shall be tested on the chassis dynamometer by applying of the UNECE Global Technical Regulation No Worldwide the individual vehicle road load settings as determined best possible harmonized Light vehicles Test Procedure (ECE/TRANS/180/Add.15). following the procedure prescribed in Annex 4 of the UNECE Global The road loads shall not account for the mass added to the vehicle Technical Regulation No Worldwide harmonized Light vehicles during the RDE test, e.g. the co-pilot and the PEMS equipment. Test Procedure (ECE/TRANS/180/Add.15). The road loads shall not account for the mass added to the vehicle during the RDE test, e.g. the co-pilot and the PEMS equipment. For In-Service-Conformity testing the distance specific CO 2 emissions shall be taken from the COC paper of the vehicle. Reasoning: During type approval, the values of the COC paper are not fixed yet, so the CO 2 values should be determined as best as possible for the individual vehicle. In order to avoid unnecessary testing burden for in-service conformance, the CO 2 values from the COC paper should be used for ISC. 13

17 RDE package 4, , L 175/ , L 175/124 Proposed amendments to RDE package 4 Appendix 6 Appendix 6 Topic: WLTP-Driving resistance, Veline für ISC WLTP-Driving resistance, Veline für ISC The driving resistance coefficients f0, f1, f2 are the target WLTP road load values for the individual vehicle to be PEMS tested, as defined in point 2.4 of sub-annex 4 of Annex XXI TMWLTP is the WLTP test mass of the individual vehicle to be PEMS tested, as defined in point of Annex XXI. The Veline shall be calculated from the vehicle type approval test in the WLTC according to the test procedure described in UNECE Global Technical Regulation No Worldwide harmonized Light vehicles Test Procedure (ECE/TRANS/180/Add.15) The driving resistance coefficients f0, f1, f2 are the target WLTP road load values for the individual vehicle to be PEMS tested, as defined in point 2.4 of sub-annex 4 of Annex XXI TMWLTP is the WLTP test mass of the individual vehicle to be PEMS tested, as defined in point of Annex XXI. For vehicles subject to ISC testing, the driving resistance coefficients and the WLTP test mass shall be taken from the certificate of conformity. The Veline shall be calculated from the vehicle type approval test in the WLTC according to the test procedure described in UNECE Global Technical Regulation No Worldwide harmonized Light vehicles Test Procedure (ECE/TRANS/180/Add.15). Reasoning: The reference data for one set of data evaluation shall be coming from the same test basis. For tests in application of certification, the data shall be taken from the vehicle, because of data availability at that point in time. For ISC the data shall be based on certified data, e.g.: data from the certificate of conformity. Our focal point is stronger on the point of using the data from one test basis only. 14

18 RDE package 4, , L 175/ , L 175/124 Proposed amendments to RDE package 4 Appendix 7a, Section Appendix 7a, Section Topic: Data pre-processing 3. TRIP INDICATORS 3.1. Calculations Data pre-processing The T4235 Hanning filter performs the following calculations: The smoother starts with a running median of 4, which is centred by a running median of 2. The filter then re-smoothes these values by applying a running median of 5, a running median of 3, and hanning (running weighted averages). Residuals are computed by subtracting the smoothed series from the original series. This whole process is then repeated on the computed residuals. Finally, the smoothed final speed values are computed by summing up the smoothed values obtained the first time through the process with the computed residuals. The correct speed trace builds the basis for further calculations and binning as described in paragraph Topic: Data pre-processing 3. TRIP INDICATORS 3.1. Calculations Data pre-processing The T4235 Hanning filter performs the following calculations: The smoother starts with a running median of 4, which is centred by a running median of 2. The filter then re-smoothes these values by applying a running median of 5, a running median of 3, and hanning (running weighted averages). Residuals are computed by subtracting the smoothed series from the original series. This whole process is then repeated on the computed residuals. Finally, the smoothed final speed values are computed by summing up the smoothed values obtained the first time through the process with the computed residuals. The correct speed trace builds the basis for further calculations and binning as described in paragraph If the Hanning filter has to be applied, the smoothed speed signal shall be used for all subsequent calculations and data processing (including verification of dynamic trip conditions and calculation of intermediate results). Reasoning: In the current version of the legislation, the criteria for valid speed signals do not allow efficient and unambiguous data and post processing. It is not clear which parts of the post processing and calculations should use the smoothed speed signal acquired from the application of the Hanning filter according to Appendix 7a. The scientifically precise description of the Hanning filter algorithm is currently not provided which may lead to incorrect or differing implementations. Currently, no mathematically precise definition of the Hanning filter is contained in the legislation, only a brief and insufficient description. A future version of the legislation should contain a detailed and precise description complying to scientific standards in order to prevent erroneous implementations derived from differing, maybe unreliable sources. 15

19 RDE package 4, , L 175/ , L 175/124 Proposed amendments to RDE package 4 Annex IIIA Paragraph 7.6 Annex IIIA Paragraph 7.6 Idle phase after start Idle phase after start 7.6 The idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s. 7.6 At the beginning of the trip, the idling immediately after the first ignition of the combustion engine shall be kept to the minimum possible and it shall not exceed 15 s for a stationary vehicle. Reasoning: For OVC-HEV, the first ignition of combustion engine may occur after several km of trip. As the vehicle is still moved by electric way, there is no need to limit the idle period. 16

20 RDE package 4, , L 175/ , L 175/124 Proposed amendments to RDE package 4 Annex IIIA Paragraph 9.5 Annex IIIA Paragraph If during a particular time interval the ambient conditions are extended in accordance with point 5.2, the pollutant emissions during this particular time interval, calculated according to Appendix 4, shall be divided by a value of 1,6 before being evaluated for compliance with the requirements of this Annex. This provision does not apply to carbon dioxide emissions. 9.5 If during a particular time interval the ambient conditions are extended in accordance with point 5.2, the raw pollutant emissions during this particular time interval, calculated according to Appendix 4, shall be divided by a value of 1,6 before being evaluated for compliance with the requirements of this Annex. This provision does not apply to carbon dioxide emissions. The values in the data exchange file #1 shall not be corrected by the value of 1.6 if application is necessary, but for all applicable values in the data reporting files the correction shall be factored in. Reasoning: Clarification is needed on when the extended boundary condition factor of 1.6 is applied, and how it is documented. The regulations currently state that the factor is to be applied "before being evaluated for compliance". This is inline with JRC Q+A document Ref. Ares (2017) /09/2017, but even more precise. 17

21 RDE package 4, , L 175/ , L 175/124 Proposed amendments to RDE package 4 Annex IIIA, Appendix 4, point 11 Annex IIIA, Appendix 4, point 11 Topic: How to handle negative values Topic: How to handle negative values Calculating the instantaneous mass emissions of gaseous components 11. The instantaneous mass emissions [g/s] shall be determined by multiplying the instantaneous concentration of the pollutant under consideration [ppm] with the instantaneous exhaust mass flow rate kg/s], both corrected and aligned for the transformation time, and the respective u value of Table 1. If measured on a dry basis, the drywet correction according to point 8.1 shall be applied to the instantaneous component concentrations before executing any further calculations. If occurring, negative instantaneous emissions values shall enter all subsequent data evaluations. Parameter values shall enter the calculation of instantaneous emissions [g/s] as reported by the analyser, fow-measuring instrument, sensor or the ECU. The following equations shall be applied: Calculating the instantaneous mass emissions of gaseous components 11. The instantaneous mass emissions [g/s] shall be determined by multiplying the instantaneous concentration of the pollutant under consideration [ppm] with the instantaneous exhaust mass flow rate kg/s], both corrected and aligned for the transformation time, and the respective u value of Table 1. If measured on a dry basis, the drywet correction according to point 8.1 shall be applied to the instantaneous component concentrations before executing any further calculations. If occurring, negative instantaneous emissions values and exhaust flow values shall enter all subsequent data evaluations. Parameter values shall enter the calculation of instantaneous emissions [g/s] as reported by the analyser, fowmeasuring instrument, sensor or the ECU. Negative vehicle speed values should be set to zero. If the final test result (after evaluating MAW or SPF) in [mg/km] or [#/km] is negative, it should be set to zero. The following equations shall be applied: Reasoning: It is not clearly defined if negative exhaust flow and speed values should be used for further calculations or set to zero. We decided that it makes sense to use negative values for the exhaust flow (due to pulsation and so on ) but it doesn t make sense to calculate with negative speed values so those should be set to zero. If the final test result is negative (due to negative exhaust flow values and negative concentrations) it should be set to zero. 18

22 RDE package 4, , L 175/ , L 175/124 Proposed amendments to RDE package 4 Annex IIIA, Appendix 8 Annex IIIA, Appendix 8 ( Change Appendix 8 according to the directions in this paragraph] The data set shall be updated according to detailed proposal for updating in annex 1 to this sheet. Reporting file #2 and #3 shall be updated with emission results including ki-factors Reporting file #4 shall be created for emission results of OVC-Hybrid vehicles according to appendix 7c data evaluation Reasoning: Appendix 8 dataset was not updated with regulation 2017/1154/EC ( RDE Package 3 ) and with new detailed provisions in RDE Package 4 a general update of the dataset is required to reflect the procedural changes and the changes in the data evaluation methods. 19

23 RDE package 4, , L 175/ , L 175/124 Proposed amendments to RDE package 4 Annex IIIA/Appendix 1 / Appendix 7b Annex IIIA/Appendix 1 / Appendix 7b Topic: Verification of altitude gain, independent map Topic: Verification of altitude gain, independent map , Table 1 Test Parameters , Table 1 Test Parameters ,Appendix 7b, Section 3 3. GENERAL REQUIREMENTS The cumulative positive elevation gain of a RDE trip shall be determined based on three parameters: the instantaneous vehicle altitude h GPS,i [m above sea level] as measured with the GPS, the instantaneous vehicle speed v i [km/h] recorded at a frequency of 1 Hz and the corresponding time t [s] that has passed since test start. Footnote 9 extended by: Definition of barometric pressure equation Definition of requirement to calibrate the altitute offset at the beginning of the test by the geopgraphic altitude of the trip starting point. Definition of a standardized filtering method It should also be considered to revise the specification of the sensor for ambient pressure in Table 4, Section 8 of Appendix 2 in (Accuracy, Noise, Drift, allowances) ,Appendix 7b, Section 3 3. GENERAL REQUIREMENTS The cumulative positive elevation gain of a RDE trip shall be determined based on three parameters: the instantaneous vehicle altitude h Pres,i [m above sea level] as derived the ambient pressure signal using the barometric equation, the instantaneous vehicle speed v i [km/h] recorded at a frequency of 1 Hz and the corresponding time t [s] that has passed since test start Appendix 7b, Section 4 and 5 4. CALCULATION OF CUMULATIVE POSITIVE ELEVATION GAIN 4.1. General The cumulative positive elevation gain of a RDE trip shall be calculated as a three-step Appendix 7b, Section 4 and 5 The two sections 4 and 5 are to be reworked under the following boundary conditions: Screening and the use of a topographic map can be removed as the altitude 20

24 procedure, consisting of (i) the screening and principle verification of data quality, (ii) the correction of instantaneous vehicle altitude data, and (iii) the calculation of the cumulative positive elevation gain. 5. NUMERICAL EXAMPLE Tables 1 and 2 show how to calculate the positive elevation gain on the basis of data recorded during an on-road test performed with PEMS. For the sake of brevity an extract of 800m and 160s is presented here. Reasoning: signal from the pressure transducer will not show step changes. Correction of instantaneous vehicle data can be removed. Remove additional data smoothing, fully handled in Footnote 9, see above The current text in the regulation is ambiguous and allows too much interpretation. The use of a map in daily practice is too difficult to facilitate in an efficient manner. As we have already the ambient pressure sensor defined in the current legislation as a preferred option for altitude measurement, we propose to use it also in this context. The target is to define a methodology, which is straightforward and can be fully automated without the need for additional input data from outside the test system. 21

25 Annex 1 of VDTÜV Input for RDE from the German Digital RDE Round Robin for Appendix 8 Table 1 Header of the data exchange file Insert after Parameter Description Unit Line I or change of Line C I1 Type of RDE test [hot start or cold start] C13 Vehicle category [M1 or N1 Group X or M2 or N2] I13 Vehicle maximum speed [km/h:yes/no] and speed limiter Flag for MSV [n/a or yes] Type of SPV [n/a or e.g. hearse] I15 Type of Hybrid [n/a or NOVC-HEV or OVC-HEV] Exhaust aftertreatment [yes or no] with periodic regeneration RDE trip with [yes/no] regeneration Ki CO total trip / [e.g.:1.01;additive] application Ki THC total trip / [e.g.:1.01;additive] application Ki NOx total trip / [e.g.:1.02;multiplicative] application Idle exhaust mass flow [ g/sec] 22

26 Table 1 Header of the data exchange file: continued Insert after Line I or change of Line C Parameter Description Unit I25W WLTP test mass [kg] I25N NEDC test mass [kg] C32 Vehicle test mass (1) [kg/% (2) ] C56 Precon Drive Date [day:month:year] I56 Precon Drive Duration [Minutes] Precon drive average [km/h] speed Precon drive max. [km/h] speed Soak time start [h:min] Soak time end [h:min] Soak Temp min max [(10;20 deg C] Average soak [deg C] temperature in last 3 hours of soak RDE test date [day:month:year] I58 Ignition on [sec] Start of drive [sec] Start of engine [sec] 23

27 Table 1 Header of the data exchange file: continued Insert after Parameter Description Unit Line I or change of Line C Start of first window [sec] End of cold start [sec] Stop time in cold start [sec] Average speed during [kmh] cold start Max. Speed during cold [km/h] start Hybrid: cumulative [km or n/a] operation distance in city of ICE Stop of engine [sec] Stop of drive [sec] Stop of last window [sec] XXY Hanning filter for [yes/no] vehicle speed applied Rural speed operation, [60:90] min/max Km/h XXX Pems test family [MS-OEM-X-Y] (2) Percentage shall indicate vehicle load 24

28 Table 1 Header of the data exchange file: continued Insert after Line I or change of Line C Parameter Description Unit C132 Pems validation results THC C133 Pems validation results CH4 C134 Pems validation results NMHC C135 Pems validation results PN C136 Pems validation results CO C137 Pems validation results CO2 C138 Pems validation results NOx [mg/km;%;delta mg/km] (6) [mg/km;%;%; delta mg/km] (6) [mg/km;%;%; delta mg/km] (6) [#/km;%;%; delta #/km] (6) [mg/km;%;%; delta mg/km] (6) [g/km;%;%; delta g/km] (6) [mg/km;%;%; delta mg/km] (6) (6) (.) Percentage shall indicate the deviation from the laboratory reference. Delta shall indicate the absolute deviation from the laboratory reference 25

29 Table 2 Body of the data exchange file; Line (1) Time trip [s] Vehicle speed Sensor [km/h] Vehicle speed GPS [km/h] Vehicle speed ECU [km/h] Insert this item Vehicle speed with Hanning filter if req d For app. 7a, 7c and for app. 5 [km/h] 26

30 Table 3 Reporting file #1 Insert after Line I or change of Line C Parameter Description Unit I3 Longest vehicle stop [sec] Number of stops > 10 [e.g.:5] sec Idle after engine start [sec] I8 I39 I71 I101 I100 Max elevation during trip Min and max of ambient temperature Number of positive accelerations in city Number of positive accelerations in rural part Number of positive accelerations on motorway Highway percentage of speed >145 km/h [m above sea level] [e.g.:10;25 deg C] [250] [456] [287] [e.g.: 0.3%] 27