1. ACEA comments on EU WLTP issues EU WLTP, 30 TH OF NOVEMBER 2015 1 30 November 2015

2. NUMBER OF TESTS. NO DECISION IN EU WLTP UP TO NOW. JRC analysis shown in correlation group 10/2015: Accuracy increases only by 0.43 g/km by going from 1 to 3 measurements. Is that huge burden justified by a potential influence of 0.4 g/km?

3. Current text proposal for COP testing under WLTP: Imagine testing a vehicle with and without engine insulation. Testing as described in the application to demonstrate the CO 2 -potential requires several tests with and without engine insulation.  Vehicle will have too much kilometres to be sold to the customer.* (It already receives ~100km in a normal COP.)  Vehicle is somehow damaged by the rebuilding due to different hardware requirements.  Additional soak chambers required. Why should an Eco-Innovation work differently in a customer vehicle? If so, a re-certification would be required anyway. COP is a quality check, not a functional test. Proposal: Do not require testing. Require a check, that this eco-innovation is actually installed in the vehicle in the type approved form. E.g. by checking serial- / type-numbers of relevant parts or components. Effect and way forward COP FOR ECO INNOVATIONS *Some may argue: "Why not selling as a used car and building a new one for that customer?" But then in fact you built a vehicle for the purpose of COP-testing, which is obviously not in the spirit of COP-testing.

4. The principle of achieving more accurate results is welcomed. But the current discussion is far away from a robust concept:  Hybrids not addressed.  Correction function is not validated by measurements.  Analysis within phase 1 shows a lack of consistency  EER.  No text proposal available. This issue is on the agenda in phase 2 in WLTP, where it can be assessed in an appropriate manner. Intermediate solution could be to introduce tolerances.  EU idea of correcting for drive trace deviations DRIVE TRACE CORRECTION FUNCTION Document from WLTP Phase 1.

5. Summary and conclusion EU WLTP ACEA VIEW  WLTP should be harmonized, accurate, repeatable, representative, error-free and feasible. IssueACEA viewJustification COP Evolution factor The proposed 0.96 will cover only parts, but may be acceptable. Measuring "Evo-factors" for the majority of the vehicles increases test burden in an unnecessary manner. COP of Eco- Innovations Check should be based on installed parts. Measurement is a huge effort, vehicles may have to be re-built, and there is no connection to quality checks like in COP. COP frequencyMore time needed.Experts to be asked to develop (statistical) criteria for frequency. Number of testsTake factor "1.000" for all three dCO2-factors. No decision by EU WLTP taken up to now (issue was adopted in IWG in Tokyo 10/2015). The increase of accuracy is minor, the huge increase of testing effort therefore not justifiable. Drive trace correction Discuss and further develop within WLTP phase 2 No validation by measurements available, correction obviously covers only parts of unrepresentative driving. There are indices in place to monitor or check against a tolerance. TransparencyData access should be decided with reasonable judgement. Access should go via the authority. Transparency is welcomed as long as it not violates safety issues, data privacy or undermines competitiveness of European industry.

6. Thank you for your attention www.acea.be