IMPLEMENTING THE WLTP-GTR: PROCEDURAL CONCEPT AND NEXT STEPS

Comments from Italy

With reference to the discussion paper on procedural concept and proposed steps to implement WLTP-GTR, the following reflections are proposed to your attention and for consideration during the discussion on 4th February meeting.

As general comment the approach proposed, if not unrealistic, it is extremely ambitious in terms of activities to be carried out in relation to the short time indicated.

In particular, the hypothesis to transpose the WLTP GTR in the European Euro 5 & 6 Regulations introducing a new Annex XX (Paragraph 1, item a) and b) of the document) would require to tackle with the following aspects by July of this year:

  • To perform the evaluation on the eventual European “weighting factors” or other elements of correction, to take into account the issue related to the lack of representativeness raised by France and Italy;
  • To complete the NEDC – WLTP correlation exercise to identify correlation factor for CO2;
  • To evaluate the need and eventually launch a similar initiative to identify correlation for regulated pollutant emissions, that we deem to be carefully considered;
  • To complete the current WLTP GTR with the missing parts (WLTP 1b) in advance (or in parallel) with respect to the activity of the UN/ECE Informal Group, with the high risk to introduce inconsistencies;
  • To update the administrative provisions of the Type-approval regulations, which will imply the revision of official documents (i.e. Annex VIII and CoC) and will affect the informatics system implemented in the National Administrations

Frankly, performing all these tasks in a so short time seems to be very difficult. In addition, it is not very effective to develop in parallel in Brussels and in Geneva the elements necessary to complete the WLTP procedure. The risk would be the duplication of work and possible extra activity to align the outcome from European and ECE if not fully coherent.

Concerning the UN/ECE Regulation issues there are pros and cons for all the options proposed. The main complications are connected again with the calendar constrains. The WLTP GTR cannot be properly completed in a too short time, the risk is to jeopardize the quality of the work.

The timing goal indicated by the Commission is not compatible with the development time necessary in UN/ECE, and this is the reason for the complex options proposed.

All this heavy work and complexity could be avoided if a more realistic calendar for the European implementation of the WLTP procedure would be adopted.

Italy recommends to adopt a new calendar, considering the application of the WLTP procedure starting from post 2020; this approach would allow to correctly transpose the WLTP GTR in the ECE Regulation following any of the proposed options. Therefore, a more realistic calendar for the application of WLTP procedure would be:

  • easier to be implemented by the National Administration,
  • more coherent with the principles of “smart regulation” adopted in CARS 2020.
  • more in line with the recommendation from the industry which would not be affected by an additional burden during the 2017-2020 period.

For the above-mentioned reasons the option for a revision of the timing for the implementation of the WLTP procedure in the European legislation should be taken into consideration.

We believe that this approach would be in line with the text of the revision of Regulation 443/2009/EU on CO2 emissions which is about to be published where it is said that “a new, more realistic and reliable test procedure should be agreed as soon as feasible” which is slightly different from the text of your paper “….WLTP should be implemented as early as possible”.

Concerning the working method it would be preferrable to deal at least within MVEGwith the “dedicated administrative matters” in order to ensure the transparency of the process at the EU level.

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