1. India’s Comments on EPPR-19-17(PART - B1)

2. Sl No
Clause No
Indian proposal
Justification 1
Title of Table B.1.-3:
Table B.1.-3: sub-classification criteria for class 1 two wheelers light motor vehicles
The expression” light motor vehicle” does not convey any useful meaning and is not defined 2
Title of Table B.1.-4:
Table B.1.-4: sub-classification criteria for class 2 two wheelers light motor vehicles
Same as Sl. No.1 3
Title of Table B.1.-5:
Table B.1.-5: sub-classification criteria for class 3 two wheelers light motor vehicles

3. Sl No
Clause No
Indian proposal
Justification 4
4.1
Vehicle type" means a category of two-wheeled motor vehicles that do not differ in the following essential respects as:
The term “vehicle type” is used for administrative purposes to decide the implementation dates for new and existing types.
Being GTR, this term has no relevance here.
Moreover, there is duplication between family definition given in ###.Also WLTP does not have this terminology.
4.1.1
"Equivalent inertia" determined in relation to the mass in running order as prescribed in paragraph 3.3, to this regulation, and [ India to give proposal]

4. Sl No
Clause No
Indian proposal
Justification 5
4.2
The fuel tank shall be filled to at least 90 per cent of rated capacity and the other liquid containing systems (except those for used water) to 100 per cent of the capacity specified by the manufacturer
The presence of used water does not have relevance to motorcycles 6
4.2 Note
In the case of two wheelers, working on gaseous fuels, the fuel tank shall be filled up to the permitted capacity mentioned in the Regional regulations.
The fuel tanks for gaseous fuel vehicles, due to safety consideration, limitation of amount of fuel to be filled is specified in safety regulation. If current scope of this GTR is limited to gasoline and diesel vehicles, there is no need to add this note now

5. Sl No
Clause No
Indian proposal
Justification 7
4.3
Sum of unladen vehicle mass and driver’s mass. The driver’s mass is applied in accordance with paragraph 3.4. above below.
Editorial. 8
4.8
"Maximum vehicle speed" (vmax) is the maximum speed of the vehicle as declared by the manufacturer, measured in accordance with Appendix 1 and Appendix1.1 of Annex X of European of Union (EU) Directive 95/1/EC Regulation (EU) No (on the maximum design speed, maximum torque and maximum net engine power of two- or three-wheel motor vehicles).
1. Directive 95/1/EC has been replaced by Delegated Regulation and reference to latest document is preferred.
2. A GTR on this subject is in the action plan of EPPR. Reference to EU regulation can be replaced with reference to GTR once it is ready.

6. Sl No
Clause No
Indian proposal
Justification 9
4.9
"Maximum net engine power" is the maximum net engine power of the vehicle as declared by the manufacturer, measured in accordance with Appendix 2, Appendix 2.2, Appendix and Appendix 2.3 of Annex X of European of Union (EU) Regulation (EU) No ISO 4106:[2004] (Motorcycles -- Engine test code -- Net power).
Latest EU regulation to be referred, which is intended for regulatory purposes.
A GTR on this subject is in the action plan of EPPR. Reference to EU regulation can be replaced with reference to GTR once it is ready.

7. This definition has no relevance in this GTR and is related to OBD.Sl No
Clause No
Indian proposal
Justification 10
4.15
Catalytic converter type’ means a category of catalytic converters that do not differ as regards the following:
(a) number of coated substrates, structure and material;
(b) type r separable exhaust system units that can be replaced;
Not in WLTP. See also Sl. 4 11
4.16
‘Cold-start device’ means a device that temporarily enriches the air/fuel mixture of the engine or any device/means which can assist to start the engine thus assisting the engine to start;
This current wording only for PI engines. Modified text will cover CI engines (e.g. Glow plugs) also. 12
4.18
‘Communication protocol’ means a system of digital message formats and rules for messages exchanged in or between computing systems or units;
This definition has no relevance in this GTR and is related to OBD.
The requirements are covered in OBD GTR.

8. Sl No
Clause No
Indian proposal
Justification 13
4.20
‘Defeat device’ means any element of design which senses temperature, vehicle speed, engine rotational speed and/or load, drive transmission gear, manifold vacuum or any other parameter for the purpose of activating, modulating, delaying or deactivating the operation of any part of the emission control and exhaust after-treatment system and which that reduces the effectiveness of the emission control system under conditions which may reasonably be expected to be encountered in normal vehicle operation and use. Such an element of design may not be considered a defeat device if
(a)The need for the device is justified in terms of protecting the engine against damage or accident and for safe operation of the vehicle; or
(b)The device does not function beyond the requirements of engine starting; or
(c)Conditions are substantially included in the Type 1 test procedures.
Aligned
with WLTP 3.5.7

9. Sl No
Clause No
Indian proposal
Justification 14
4.25
‘Engine control unit’ means the on-board computer that partly or entirely controls the engine or engines of the vehicle and all emission related devices/systems;
Control of engine alone is not enough. ECU must control the emission controls systems 15
4.27
‘Exhaust gas recirculation (EGR) system’ means part of the exhaust gas flow led back to or remaining in the combustion chamber of an engine in order to lower the combustion temperature;
For better clarity. The exhaust gases inside the chamber, which has not been swept out, cannot be considered as EGR. 16
4.28
‘Fuel requirement’ by the engine means the type of fuel normally used by the engine, i.e. Petrol;
May be deleted as it does not add any useful information 17
4.30
‘maximum vehicle speed’ of a vehicle means the maximum achievable out in European Union (EU) Directive 95/1/EC;
May be deleted to avoid duplication of clause no (See Sl. No.8)

10. Sl No
Clause No
Indian proposal
Justification 18
4.33
‘Original equipment pollution-control devices’ mean pollution-control devices including oxygen sensors, catalytic converter types, assemblies of catalytic converters, particulate filters or carbon canisters for evaporative emission control covered by the [approval] / [certification] and originally delivered for the [approved] / [certified] vehicle;
Delete as this is needed only if requirements of after market parts are covered. 19
4.36
‘Particulate matter’ (PM) means any material collected on the filter media from components of the diluted vehicle exhaust as specified in this GTR. gas which are removed from the diluted exhaust gas at a maximum temperature of 52.0 °C by means of the filters described in the test procedure for verifying average tailpipe emissions;
WLTP clause number 3.6.2

11. Sl No
Clause No
Indian proposal
Justification 20
4.38
‘Pollution-control device type’ means a category of pollution-control devices that are used to control pollutant emissions and that do not differ in their essential environmental performance and design characteristics;
Not in WLTP. See also Sl. 4 21
4.45
Propulsion unit’ means a combustion engine, an electric motor engine, any hybrid application or a combination of those engine types or any other engine type;
Editorial

12. Sl No
Clause No
Indian proposal
Justification 22
4.46
Reference mass’ means the mass in running order of the vehicle increased with the mass of the driver (75 kg) and if applicable plus the mass of the propulsion battery;
Since hybrid is out of scope 23
4.49
‘Stop-start system’ means automatic stop and start of the propulsion unit to reduce the amount of idling, thereby reducing fuel consumption, pollutant and CO2 emissions of the vehicle;
Definition need not cover the purpose 24
4.50
‘Super-charger’ means an intake air compressor used for forced induction of a combustion engine, thereby increasing propulsion unit performance;
Wltp? 25
4.52
‘Turbocharger’ means an exhaust gas turbine-powered centrifugal compressor boosting the amount of air charge into the combustion engine, thereby increasing the propulsion unit performance;

13. Sl No
Clause No
Indian proposal
Justification
4.##
New clause
"Predominant mode" for the purposes of this gtr means a single mode that is always selected when the vehicle is switched on regardless of the operating mode selected when the vehicle was previously shut down.
New definition to be added in line with WLTP to take care of Indian comment on (Row nummer 145 of document EPPR (B2)

14. Sl No
Clause No
Indian proposal
Justification 26
6.1
[Where rounding is required, values ≥ 5 shall be rounded up and values < 5 rounded down.]
When the digit next beyond that last place to be retained, is
(a) less than 5, retain the last digit unchanged. (E.g becomes 1.24)
(b) greater than 5, increase the last digit by one. (E.g becomes 1.25)
(c) Equals 5, and there are no digits beyond this, or only zeros, increase the last digit by one, if the last digit is odd (E.g becomes 1.24)and retain the last digit unchanged if it is even(E.g becomes 1.24)
d) Equals 5, and there are digits beyond this, increase the last digit by one. (E.g becomes 1.25)
Current GTR 2 gives reference to ASTM E The proposed language has the same meaning as per ASTM E
India is not locate a corresponding ISO.

15. Through out the document prefer to use decimal point instead of commaSl No
Clause No
Indian proposal
Justification 27
6.2
[Throughout this document the decimal sign is a full stop (period) "." and if used the thousands separator a comma ",".] Comment: To check system used in other GTRs
Through out the document prefer to use decimal point instead of comma 28
8 (title)
Performance requirements for the type I test of a two-wheeled vehicles motorcycle.
Editorial for better clarity 39
8,1
The principal requirements of performance are set out in point 8.2 for two-wheeled vehicles motorcycle.
Contracting Parties may also accept compliance with one or more of the alternative performance requirements set out in point 8.3 for two-wheeled vehicles motorcycle

16. Editorial for better claritySl No
Clause No
Indian proposal
Justification 30
7 (title)
General requirements applicable for manufacturers requesting whole vehicle type-approval in countries that apply mutual recognition of type-approval
Editorial. The portion proposed to be deleted is an administrative part, not applicable to GTRs 31
8 (title)
Performance requirements for the type I test of a two-wheeled vehicles motorcycle.
Editorial for better clarity 32
8,1
The principal requirements of performance are set out in point 8.2 for two-wheeled vehicles motorcycle.
Contracting Parties may also accept compliance with one or more of the alternative performance requirements set out in point 8.3 for two-wheeled vehicles motorcycle

17. Sl No
Clause No
Indian proposal
Justification 33
Table 3.1.6
Replace table with following table
It has been agreed in 17th EPPR that principal norms will be Euro 5
Class
Limits (mg/km)
Reference Fuel CO
THC
NMHC
NOx PM PI
1,000
100 68 60
4.5
As per Annex ###(corresponding to E5 CI
500 90
As per Annex ###(corresponding to B5)

18. Alternative norms
In the 17th EPPR meeting it was agreed that alternative norms can be a combined table of Euro IV and BS IV norms.
These norms are tabulated in the next slide.
Request members suggestions how to formulate the table for alternative norms.
Or, alternative norms can be regional norms, (E.g. Euro 4, BSIV and Euro 3)

19. BS IV has DF already built into the Limits.
Sub-
Class
Limits (mg/km) CO HC
NOx
HC + NOx
BSIV
Euro 4
BS-IV
BS-IV (1) 1
1,403
1,140 NA
380
390 70
790
2-1(2)
2-2
1,970
340
670 3
170
200 90
400 DF
(3)
1.3
1.2
Notes
(1)
For BS-IV, there is an option to comply with Evaporative emission norm of 6g/test (instead of 2g/test) HC + NOx norms to be tightened by 200mg/km from the values given in table.
(2)
Applicable parts of Driving cycle for BSIV are Part 1 RS cold and Part 1 RS Hot, as against Euro 4, Part 1 RS cold and Part 2 RS Hot.
BS IV has DF already built into the Limits.