ACEA Comments from 27.02.2013 ACEA still does not understand the reasoning for this proposal. This proposal increases the test burden disproportionally without generating any benefit for the consumer. Beyond that, the proposal further increases the test procedure complexity to determine individual break-off criteria for each phase test It is unclear, how all the individual test results for the phases shall be combined to a meaningful number for the customer. JP proposal does not allow the application of already agreed (fractional) Utility Factor methodology, based on RCDC cycle range (as RCDC is only defined for complete WLTC cycles) UF function is determined by statistical evaluation of real driving data and based on the vehicles overall charge depletion range. Currently there are no UFs defined for different trip styles. Even if those were available, the interpretation of these towards an overall result would be very hard to comprehend. Repetitively driven cycle phases (defined as cold test by JP) must be considered as a hot tests, as the temperature behavior over several drive cycles will lead to warm-up to normal operating temperatures over the first few phases anyhow. This questions the reasoning of the JP “dot matrix”.

ACEA (27.02.2013): Comparisson of Test Burden

following: original JP proposal as reference

Base test matrix Based on the idea to measure the emission and fuel economy (or CO2) by each phase, ● marked cold & hot tests will be necessary for each type of vehicles.

Measuring items for OVC-HEV(P-HEV) The most number of measuring items are necessary for PHEV. Following chart shows the parameters for P-HEV at Low phase in WLTC. Japan shows the simplified method for EAER calculation which is used in domestic for reference. Base Japan recommendation

Base test matrix Japanese proposal Cold CS test of M,H,ex-H Phase should be omitted and calculated like as Low Phase.