1. EPPR India comments on B1 Text 15th September 2017

2. Clause no
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Table B.1-1
EC stance- “Other than petrol and diesel can be taken out of the scope and table”
India stance to incorporate fuels for PI and CI technology based on EU-5 for CNG, LPG, gasoline with ethanol blends and diesel, bio diesel and its blends. India agrees to remove hydrogen and its blends till the technology get matured.
This provision is essential as some of the CPs are already practicing these fuels and implementation of GTR shall not restrict them.
Once we agree with the above fuels we need to incorporate fuel properties e.g. C/H ratio, density etc. for all these fuels.
Reference to be taken from WLTP GTR-15.
4.3
"Mass in running order" (mref) means the nominal mass of a vehicle as determined by the following criteria:
Sum of unladen vehicle mass and driver’s mass. The driver’s mass is applied in accordance with paragraph 4.4. below.
Wherever the expression “Mass in running order” appears in the document may be changed to unladen mass.
Definition of mass in running order para 4.3 to be deleted.

3. Clause no
Existing Text
Proposed text
Remark
4.37
[‘Particulate matter (PM)’ means any material collected on the filter media from diluted vehicle exhaust as specified in this GTR]
New text Proposed by EPPR
3.6. PM/PN
The term "particle" is conventionally used for the matter being characterised (measured) in the airborne phase (suspended matter), and the term "particulate" for the deposited matter.
"Particle number emissions" (PN) means the total number of solid particles emitted from the vehicle exhaust quantified according to the dilution, sampling and measurement methods as specified in this UN GTR.
"Particulate matter emissions" (PM) means the mass of any particulate material from the vehicle exhaust quantified according to the dilution, sampling and measurement methods as specified in this UN GTR
Definition for Particle, particulate, Particle number emissions and Particulate matter emissions based on the WLTP are ok. However to include the PN measurement the test procedure and test setup need to be worked out for L category vehicles.
JRC being the leading PMP-IWG under GRPE can be requested for assistance to develop this procedure.
To avoid delay in GTR-2 finalization this can be kept as place holder in the document till it get finalized.
Incorporating PN in GTR considering the future requirements will be needed for equipment planning with the features to measure both PM and PN together.
This is to avoid financial implications and technical complexity which will be required latter on for PN measurement as the current proposed system in GTR-2 is only for PM measurement.

4. Clause no
Existing Text
Proposed text
Remark
4.46
‘Reference mass’ means the mass in running order of the vehicle increased with the mass of the driver (75 kg);
‘Reference mass’ means the unladen mass as defined in 4.2 mass in running order of the vehicle increased with the mass of the driver (75 kg);
4.50
‘super-charger’ means an intake air compressor used for forced induction of a combustion engine, thereby increasing propulsion unit performance;
‘super-charger’ means an intake air/air fuel mixture compressor run by any means other than engine exhaust and used for forced induction of a combustion engine, thereby increasing propulsion unit performance;
Definition modified for better clarity.
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;
Definition is ok

5. Clause no
Existing Text
Proposed text
Remark
6.3
Where possible ‘°C’ shall be used for the definition of temperatures (0°C = K).
WLTP GTR-15 also uses temperature in K as equivalent to 0°C.
So EPPR shall also follow inline with WLTP for temperature conversion from °C to K and vice versa, wherever it is required to keep the uniformity across GTRs