1. Annex８　 （ ） CD-CS　break-off　criteria Proposal from Japan with ACEA Comments ( )

2. ACEA General Comments (27.02.2013)
the cd break-off criteria is of minor importance for the final FC and CO2 values, as it just gives an indication when the cd-test procedure is finished.
however, the determination of the cd BoC has a big impact on the flexibility to perform the test procedure
the basic principle of current GTR xEV test procedure is the possibility to independently perform the cd and cs tests
this is only possible with a break-off criteria that can be calculated independently of the cs test results
with a cs fuel consumption based break-off criteria, the so far agreed test procedure flexibility is not any longer guaranteed

3. According to Annex８ 5.2.4.5.1. ver（28.12.2012）
explanation
ACEA　proposal
The break-off criteria for the charge-depleting test is reached when the relative net energy change as shown in the equation below is less than 4 per cent.
Relative net energy change [per cent]
= _________NEC____________
Cycle energy demand of the test vehicle
Japanese proposal
The break-off criteria for the charge-depleting test is reached when the relative net energy change as shown in the equation below is less than [x] per cent.
＝_________NEC_______ ___
Consumed fuel energy during the CS-cold test

4. Comparison ACEA vs Japan with ACEA Comments (27.02.2013)
Merit
Demerit
ACEA proposal
・The criteria would be calculated before CD test.
CS and CD can be conducted separately
Technology neutral: criteria independent of the efficiency of the powertrain (as hard to reach for a very efficient PT as for a low efficient PT) (*)
Also DEKRA confirmed in VPII the applicability of the cycle energy demand based BoC.
・Necessary to calculate Cycle energy demand of the test vehicle for beak off criteria before test.
・The criteria of the vehicle which has a few generative efficiency would be narrow.
・Not including deceleration energy(regenerative energy).
The impact of the regenerative energy on the BoC is rather small and negligible for the final FC and CO2 values.
Japanese Proposal
・Fuel consumption is including deceleration energy.
 this is not technology neutral, as it takes into account the PT efficiencies
・similar thinking with ISO.SAE
 GTR intention is to create robust and worldwide applicable test procedures
・Necessary to conduct CS test before CD test.

5. Comparing ACEA proposal（28
Comparing ACEA proposal（28.12,2012）and Japanese proposal, The Criteria would be different at equivalent NEC.
with ACEA comments ( ):
the JP calculations demonstrate, that the ACEA proposed cycle energy demand based BoC can be defined equivalent to the JP proposed fuel consumption based BoC:
Ah　 criteria（％） Wh Ah 1 2 3 4 5 10
ACEA
proposal
Cycle energy demand
2783
7.73
0.077
0.155
0.232
0.309
0.387
0.773
Japanese
Proposal
Consu-med fuel energy
11661
32.39
0.324
0.648
0.972
1.296
1.620
3.239
360V
Equivalent NEC
The criteria decided by Japanese proposal would be around 1/3-1/5 of the criteria decided by ACEA proposal .
ACEA don’t understand this statement, as the absolute BoC criteria is the same (about 0.3 Ah)
Data　from　“OVC-HEV ACEA agreed Minutes”

6. Concerning break-off criteria, we couldn’t analyze enough by Validation２. Therefore in case of Confirmation　test, we’d like to propose to evaluate by number of vehicles including option 3.
In addition, there are possibility the vehicle does not meet break off criteria by developing new technology in the future. And it makes impossible to judge CS mode by current break off criteria.
In case Not meet to break off criteria, we propose “procedure to evaluate by plural cycle “ (from ISO 、SAE　J1711) agreement with approval authority
ACEA agrees to have a provision in case of vehicles not being able to meet the break-off criteria ( )