ENTERPRISE AND INDUSTRY DIRECTORATE-GENERAL
Consumer goods
Automotive industry
Brussels,
ENTR.F1/KS D(2009)
Initial Commission comments on ver. 1 draft of the WLTP roadmap (WLTP-03-xx),
dated 26 February 2009
(1) On page 6 it should be mentioned that LD OBD issues are to be excluded from the most urgent work towards the new test cycle but there was consensus at GRPE that LD OBD should either be addressed at a later stage by the WLTP GTR or in a separate GTR.
(2) We have some concerns on separating "off-cycle" elements, i.e. the engine operation outside the driving cycle, from the development of the test cycle. The two elements are inherently linked. The development of an "off-cycle" test, e.g. along the lines of the Heavy-Duty PEMS project, could be done in parallel to the development of the new test cycle. If necessary the EU could consider to go ahead with such development and to make results available to WLTP at a later stage.
(3) For the Commission the development of a MAC test cycle has a very high priority due to political obligations. It could be envisaged that this task is performed by the EU and results are fed back into "phase II" of the WLTP process at a later stage.
(4) For the in-use data collection of the new driving cycle the availability of regional driving statistics should be investigated. It is not clear whether sufficiently reliable data can be generated by operating fleets of test vehicles during a relatively limited time period in each region (however, test vehicles could be used to confirm the reliability of regional driving statistics).
(5) At least a "simple" version of the low ambient temperature test should be included in phase I of the work. The low ambient temperature test does not require the specification of a new driving cycle, but could be based (as today) on a part of the new general driving cycle with specifications of ambient conditions and reference fuels. If necessary, the test could be improved in phase II of the WLTP work.
(6) Reference should be made to the possibility of using existing work on more realistic driving cycles (e.g. ARTEMIS project), together with in-use data, as a basis for the development of the new driving cycle.
(7) Reference should be made to the possibility of introducing different driving modes for different vehicle categories (e.g. three categories defined by their power/mass ratio etc.), as discussed at the GRPE in January 2009.
(8) Reference should be made to the possibility of introducing random elements into the new driving cycle.
(9) Although it is unlikely that the phase II work can be finished by 2014, the start of this work should be envisaged as soon as possible and it could be (partially) performed in parallel to phase I.
(10) The Commission confirms its opinion that Durability and In-service conformity should be included in part II of the WLTP work.
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