1. India Comments on Draft OBD GTR for phase 1 Received from OBD Correspondence Group
OBD CG comments are in: this format & this format
India comments /modifications are marked in blue bold and strikethrough for deleted
Presented by
Dr. H. A. Nakhawa

2. Comments on Purpose ,Scope & Application (1/1)
Sr No
Proposal
Justification /Comments 1.
1.3. OBD stage I should not oblige manufacturers to change or add fuelling or ignition hardware and should not impose fitting of an electronic carburettor, electronic fuel injection or electronically controlled ignition coils, providing the vehicle complies with the applicable environmental performance requirements. Compliance with the OBD stage I requirements implies that if fuel delivery, spark delivery or intake air hardware is electronically controlled, the applicable input or output circuits need to be monitored, limited to the items and failure modes listed in [Table 2 of Annex 2.]
India would like to understand how to address vehicle technologies with simple carburettor and spark ignition system for monitoring OBD II requirements. 2
2. Scope & application
Deletion recommended in the proposal need to be justified.
Strikethrough is recommended so that applicability will be harmonized ,by removing the options for the CP’s .

3. Comments on General requirements (1/4)
Sr No
Proposal
Justification /Comments 1.
5.2.1 The technical requirements of this section shall be mandatory for vehicles in the scope of this gtr equipped with an the OBD stage I systems.
Editorial correction 2
Introduce the table when document gets finalized .
a. The clause numbers given in front of each topic need to be ensured for their correctness and the criteria shall be aligned with EU5.

4. Comments on General requirements (2/4)
Sr no
Proposal
Justification/Comment 3.
From the dates set out in point of Annex IV, vehicle (sub-)categories L3e to L7e shall be equipped with an The OBD stage I system which shall monitorss and reports for any electric circuit and electronics failure of the emission control system and which is triggered when the emission thresholds as laid down in paragraph 5.5. Annex VI (B2) are being exceeded. OBD stage I systems for these vehicle (sub-)categories shall also report the triggering of any operating mode which significantly reduces engine torque.
From the dates set out in point of Annex IV and subject to Article 23(5), vehicle (sub-)categories L3e, L5e-A L6e-A and L7e-A shall in addition be equipped with an Also, OBD stage II system which shall monitorss and reportss emission control system failures and degradation which results in the OBD emission thresholds as laid down in paragraph 5.5. Annex VI (B2) being exceeded.
Editorial correction 4.
L-category vehicles Vehicles in the scope of this gtr shall be equipped with an OBD system so designed, constructed and installed in a vehicle as to enable it to identify types of deterioration or malfunction over the entire useful life of the vehicle. In achieving this objective, the approval authority shall accept that vehicles which have travelled distances in excess of the distance specified in type V test by the contracting party [Type V durability distance in Section (A) of Annex VII to Regulation (EU) No 168/2013] may show some deterioration in OBD system performance such that the OBD emission thresholds given in paragraph 5.5. [Section (B) of Annex VI to Regulation (EU) No 168/2013] may be exceeded before the OBD system signals a failure to the driver of the vehicle.
We can include Euro 5 distance criteria once it gets confirmed, till then CP can have their regional option.

5. Comments on General requirements (3/4)
Reference Para
Proposal
Justification/Comment 5.
For direct injection positive ignition engines, any malfunction that could lead to emissions exceeding the particulate mass (PM) OBD emission thresholds provided for in paragraph 5.5. Section B of Annex VI to Regulation (EU) No 168/2013 shall be monitored in accordance with the requirements of this section Annex for compression ignition engines.
Editorial correction 6.
A sequence of diagnostic checks shall be initiated at each engine start and completed at least once provided that the correct test conditions are met. The test conditions shall be selected in such a way that they all occur in the course of normal driving as represented by the Type I test of GTR No.2 . If the failure cannot be reliably detected under the Type I of GTR No.2 test conditions, the manufacturer may propose supplemental test conditions that do allow robust detection of the failure to be agreed with the technical service to the satisfaction of the approval authority.
For better clarity

6. Comments on General requirements (4/4)
Sr No
India Proposal
Justification/Comment 7.
A manufacturer may disable the OBD system if its ability to monitor is affected by low fuel levels. or below the minimum state of charge of the propulsion or electric system batteries (maximum discharge of capacity). Disablement shall not occur when the fuel tank level is above [20 per cent]of the nominal capacity of the fuel tank.
HEV/EV is outside the scope of this GTR.
Values of 20% or any other values needs further review. For Indian conditions and vehicle fuel tank configuration & location this value may very. India will comeback on this point. 8.
A manufacturer may disable the OBD system at ambient engine starting temperatures below [266.2 K (- 7 deg. C)] or at elevations over [2500 metres] above sea level, provided it submits data and/or an engineering evaluation which adequately demonstrate that monitoring would be unreliable in such conditions. It may also request disablement of the OBD system at other ambient engine starting temperatures if it demonstrates to the authority with data and/or an engineering evaluation that misdiagnosis would occur under such conditions. It is not necessary to illuminate the malfunction indicator (MI) if the OBD thresholds are exceeded during regeneration, provided no defect is present.
The boundary condition mentioned here are to be examined for single cylinder air cooled engines as this seems to be drawn from multi cylinder water cooled engines, particularly from passenger car. So criteria needs further review, Moreover in the tropical countries like India the temperature of – 7 deg C may not be encountered . India will comeback on this point.

7. Comments on Minimum monitoring requirement (1/1)
Sr No
India Proposal
Justification 1
Title of Annex 2
Minimum monitoring requirements for electric circuit diagnostics of an On-Board Diagnostic (OBD) system stage I .
Editorial and inline with EPPR 8-14,
RVCR 44/2014

8. General comments
Requirements related to EV/HEV need to be deleted from whole document wherever it appears as EPPR-IWG has limited the scope only to the conventional fuel [e.g In para of General Requirements].
In various para’s there are cross references to other annexes /para’s. India proposes to keep all references in square brackets till the document gets finalized with necessary corrections.
India proposes GTR 5 to be looked into wherever appropriate to refer for the definitions and terminologies in order to keep the uniformity across GTR [e.g. Functional safety related to OBD system ].

9. Thanks