ACEM proposalsfor Euro 5 implementationExecutive summary

MCWG22 September 2016

Requirement ACEM concerns ACEM proposals Actions required

Timeline for implementation

EC’s Environmental Study on the feasibility of EURO 5 is considerably delayed. Industry studies also identify critical areas where revision of R168/2013 is necessary to ensure proper Euro 5 implementation. The Euro 5 implementation date of 2020 is incompatible with both the legislative revisions of R168/2013, and with required industry lead-time.

- Define final Euro 5 requirements. - Amend R168/2013 and its delegated acts to allow sufficient lead-time for industry to develop and manufacture compliant vehicles.

Amend R168/2013 Annex IV to ensure that the Euro 5 implementation dates take into account minimum industry lead-time (i.e. at least 2 years from publication of amended Regulation and delegated acts).See slide 8

On boarddiagnosis systems(OBD II)

Misfiredetection

Due to considerably low inertia (compared to cars), motorcycle engines are more sensitive to external influences (road conditions, drivetrain, etc.). This creates problems in robust misfire detection, particularly at low and high RPM, and at low loads.

Redefine the zone where engines can be reliably monitored, making that zone proportional to the range used for cars.

Modify article 3.3.2. of Annex XII to the RVCR (44/2014).See slides 10

Catalyst monitoring

Shorter exhaust systems (compared to cars), cause O2 sensor signal distortions from backflow and diffusion.

Reliable cat. monitoring necessitates significant catalyst and muffler redesign (due to vehicle space restrictions), requiring additional lead-time, particularly for existing vehicle types.

Accurate cat. monitoring depends on engine load, which may impact the monitoring of IUPR. Concerns also remain over errors in the current IUPR text.

- Phase-in appropriate OBD thresholds (OTLs) and IUPR in order to introduce OBDII.- Correct remaining IUPR omissions and errors.- 2 years are required between the implementation date for new vehicle types and that for existing types.

- Maintain current Euro 4 OTL (OTL 1) for Euro 5 by amendment of R168/2013 Annex IV. Introduce OTL 2 in a later stage after a review process. See slide 12- Introduce IUPR monitoring at Euro 5 via amendment to Annex XII of RVCR (44/2014). Introduce the minimum 10% IUPR threshold in a later stage only after a review process. See slide 12

Requirement ACEM concerns ACEM proposals Actions required

Durability

Durability accumulation cycle-related

concerns

The Euro 5 step will remove AMA, as one of the two cycle options (the other being SRC-LeCV).

Keep AMA in Euro 5, as the only established & acceptedworldwide harmonised cycle, as an option with SRC-LeCV.

Modify paragraph 3.4.2. of Annex VI of the REPPR (134/2014).See slide 14

The current SRC-LeCV classification results in inappropriately high engine speeds and loads compared to WMTC. This is particularly severe for low displacement and low performance motorcycles.

Align the SRC-LeCV classification with the WMTC.

Amend paragraph 2.6. of Appendix 1 to Annex VI of the REPPR (134/2014).See slide 14

Restricted testing options

compared with cars

Lack of additive option for calculated durability factor (DF) (next to existing multiplicative DF), in case of calculating pollutant levels from partial mileage accumulation (168/2013 Article 23 (b)).

Add additive option for calculated DF (next to existing multiplicative DF).

Use the additive option from paragraph 2.1.4. of Annex VII of 692/2008 in Annex VI of the REPPR (134/2014).See slide 14

No possibility to carry out bench ageing tests. Introduce the possibility to carry out bench ageing tests.

Use bench ageing option from paragraphs 1.3. and 2.2 of Annex VII of 692/2008 in Annex VI of REPPR (134/2014).See slide 14

Requirement ACEM concerns ACEM proposals Actions required

Type 1(tailpipe)

Cold-warm weighting

factors

The Euro 4 cold-warm weighting factors (30/70) for mopeds and smaller motorcycles were revised under Euro 5 (50/50) without anevidence-based study.

Retain the current Euro 4 factors for cold-warm weighting in the Euro 5 step.

Amend REPPR Annex II 6.1.1.6.2.2. Table 1-10 (replace 50/50 by 30/70)See slide 16

WMTC for non-L3 vehicles

It is still unclear whether a modified version of the WMTC will be a suitable method to test L1, L2, L5, L6 and L7 (‘non-L3’) category vehicles.

Allow choice between WMTC or R40/R47 tests with the Euro 5 limits.

Amend R168/2013 Annex IV1.1.1.4. and REPPR Annex II6.1.1.6.2.2. Table 1-10See slide 16

L6e-B(light quadrimobile)

and L2e-U

(3-wheel utility moped)

Euro 5 is technologically and economically unachievable for vehicles currently equipped with diesel engines.

The maximum engine capacity allowed (50 cc) for 4-stroke gasoline (PI) engines is not sufficientto move these vehicles.

Allow up to [XYZ] cc engine capacity for PI engines;

Amend Annex I of R168/2013.See slide 16

ACEM proposalsfor Euro 5 implementation

MCWG22 September 2016

Evolution: Euro 3 => Euro 4 => Euro 5

• The motorcycle industry has always been and will remain an active participant supportingthe development of regulation for the sector - in particular, the most recent process fromEuro 3 to Euro 5.

• However, ACEM continues to have serious concerns regarding certain specific aspects ofEuro 5 as currently proposed.

• Regulation 168/2013 requires the European Commission to carry out a study ‘to confirm’this Euro 5 step.

• This presentation outlines concrete proposals to ensure that Euro 5 can be implemented:• Modified implementation timeline• On board diagnostics (OBD)• Durability• Type 1 (tailpipe)

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Significant increases in regulatory requirements and severity from Euro 3 to Euro 5

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2006 2016 2020

EURO 3 EURO 4 EURO 5

Tailpipe emissions

Limits Euro 3 Euro 4 Euro 5 (quadricycles?)

Test cycleR40 / R47

NEDC / WMTCR40 / R47

WMTC only for L-3 vehiclesR40 / R47

WMTC for all L-category

Idle emissions Yes Yes Yes

Crankcase emissions - Yes Yes

Durability cycle - SRC-LeCV AMA SRC-LeCV AMA

Evaporativeemissions

Limits and test methods -2000 mg/test

(SHED)1500 mg/test (SHED)

15000 mg/m²/day (Permeation )

On board diagnosis systems (OBD)

OTL - OTL1 OTL 2

OBD I - Yes Yes

OBD II

Catalyst monitoring - - Yes

Misfire detection - - Yes

IUPR - - Yes

Increasing regulatory complexity and stringency

ACEM concern areas

2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Deadline Euro 5 implementation (existing types)

Deadline Euro 5 implementation (new types)

31/12/2016EC Report

to EP + Council

[Delay]

New type-approvals: +2 years

from final Euro5

ACEM proposal for implementation timeline

EC draftingAmendment to

R168/2013

Regulation 168/2013: current timeline and ACEM proposal

Regulation 168/2013

01/01/2016. Deadline for environmental effect

study

ACEM considers that some specific amendments of R168/2013 are necessary in order make Euro5 implementable

Co-decision process

OBD II - Misfire detection concerns

• Motorcycle engines have inherently less inertia than car engines, lower stability and are more subject to the influences of the road surface and the different drivetrain technologies (chains/belts/shaft) used. This puts restrictions on the areas for robust misfire detection for motorcycles.

• Motorcycle engines have many different layouts (number of cylinders/architecture) and have a variety of torque delivery profiles. Misfire detection problem areas are therefore manifested in diverse ways.

• These detection problem areas are fundamentally at low and at high rpms, and also at low loads.

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Problem areas for misfire dectection across different engines

Possible area to detect misfire

Impossible area to detect misfire

Load limit line

WMTC max + 1000 rpm

Driving point in WMTC

4 cyl. chain 2 cyl. chain 1 cylinder CVT

4 cylinder shaft

OBD II - Misfire detection, ACEM proposals

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• It is necessary to redefine the zone where engines can be reliably monitored and also to make thatzone proportional to the range used in passenger cars.

• This will require a modification of Annex XII to the RVCR (44/2014).

ACEM proposes ANNEX XII, article 3.3.2.2, to read:

The presence of engine misfire in the engine operating region bounded by the following lines:

a) The maximum nominal engine speed multiplied by 0,7 or 1000 min-1 greater than the highest speed occurring during a WMTCtest cycle, whichever is the lower;

b) Nominal idle engine speed plus 1000 min-1; (*)

c) A line joining the following engine operating points: A point on the speed line defined in (a) with the engine’s manifold vacuumat 13,3 kPa lower than that at the positive torque line; A point on the speed line defined in (b) with the engine’s manifold vacuumat 13,3 kPa lower than that at the positive torque line.

(*): for vehicles with CVT : CVT engagement engine speed + 500 min-1

OBD II - Catalyst monitoring and IUPR concerns

• Motorcycle exhaust system lengths are much shorter than incars. This leads to:

• O2 sensor signal distortion due to backflow (reverse flow from themuffler outlet)

• O2 sensor signal distortion due to diffusion (concentration fluctuationsdue to expansion)

• These distortions are shown in the highlighted sections in the graphbelow.

• Fundamental packaging restrictions of the motorcycle do notgive the same flexibility as cars for integration of components,such as:

• Catalyst• Extra O2 sensor(s)

• New/enhanced ECU(s)

• Robust technology needs to be developed to accuratelymonitor OTL2. The robustness of monitoring depends to a largeextent on engine load which limits the ability to meet theminimum in use performance (IUPR) monitoring requirements.Moreover, the current RVCR still contains omissions and errorsthat prevent IUPR from being implemented.

• Reliable catalyst monitoring requires significant catalyst andmuffler redesign, requiring additional time particularly forexisting vehicle types.

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Measurement problems exist regardless of the O2 sensor location (B, C, D, E)

AB

C

D

E

A

A

A

brown：w/o precious metalblue：with precious metalO2 sensor signal

A

B

C

D

E

OBD II - Catalyst monitoring + IUPR, ACEM proposals

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• Phase-in of appropriate OBD thresholds (OTLs) and in-use performance ratio (IUPR) is required to introduce OBDII, and correct IUPR omissions and errors.

Maintain the current Euro 4 OTL (OTL 1) for Euro 5 via an amendment of Annex IV of 168/2013. Introduce OTL 2 at a later stage only after a review process.

Introduce IUPR monitoring at Euro 5 via an amendment to AnnexXII of RVCR (44/2014). Introduce the minimum 10% IUPR at a laterstage only after a review process.

OTL IUPR

Correct IUPR omissions and errors in RVCR (44/2014)- Add sampling criteria (cfr EC Reg No 692/2008 Ann II + App 1

and 2)- Amend incorrect crossreferences:

- “point 3.2. of Annex XII” in RVCR Ann XII App 1 4.1.1. to read“point 4.2.”

- “point 3.5.” in RVCR Ann XII App 1 4.7.4. to read “point 4.5.”

[ ]

Durability - Concerns

ACCUMULATION CYCLE

• AMA continues to be the only established and accepted worldwide harmonised cycle. Moreover, AMA creates a catalyst temperature profile comparable to that of the WMTC. Under Euro 4, AMA is available as one of the two cycle options, the other one being SRC-LeCV. However, the Euro 5 step rules out AMA.

• The current SRC-LeCV classification results in inappropriately high engine speeds and loads compared to WMTC. This is particularly severe for low displacement and low performance motorcycles.

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Restricted TESTING OPTIONS compared with cars

• Lack of additive option for calculated DF (next to existing multiplicative DF), , in case of calculating pollutant levels from partial mileage accumulation (168/2013 Article 23 (b))

• No possibility to carry out bench ageing tests

Big difference

Durability - ACEM proposals

Durability accumulation cycle-related proposals

• Keep AMA for Euro 5 as option next to SRC-LeCV. This requiresamending paragraph 3.4.2. of Annex VI of the REPPR(134/2014).

• Align SRC-LeCV classification with WMTC. This requiresamending paragraph 2.6. of Appendix 1 to Annex VI of theREPPR (134/2014).

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Restricted testing options compared with cars

• Add additive option for calculated DF(next to existing multiplicative DF). Thisrequires amending Annex VI of the REPPR(134/2014) on the basis of paragraph2.1.4. of Annex VII of EC Reg 692/2008

• Add bench ageing as option. This requiresamending Annex VI of the REPPR(134/2014) on the basis of paragraphs1.3. and 2.2. of Annex VII of EC Reg692/2008

Cycle WMTC ClassVehicle maximum design

speed (km/h)Net power (kW)

1 1 vmax ≤ 100 km/h ≤ 6 kW

2 2 100 km/h < vmax < 130 km/h < 14 kW

3 3-1 130 km/h ≤ vmax < 140 km/h ≥ 14 kW

4 3-2 140 km/h ≤ vmax —

Type 1 - ACEM concerns

Cold-warm weighting factors

• The Euro 4 cold-warm weighting factors (30/70) for mopeds and smaller motorcycles at the borderof WMTC class were evidence based.

• However, under Euro 5, these factors were revised (50/50) without following a scientific process.

WMTC for L1, L2, L5, L6 and L7 (‘non-L3’) vehicles

• Under Regulation 168/2013, a modified version of the WMTC will become a single emissionlaboratory test for all L-category vehicle categories as of 2020.

• However, it is still unclear whether a modified version of the WMTC will be a suitable method to testnon-L3 category vehicles.

Diesel light quadrimobiles (L6e-B) and 3-wheeled utility mopeds (L2e-U)

• The Euro 5 step is technologically and economically unattainable for L6e-B and L2e-U vehiclescurrently equipped with diesel engines.

• The maximum engine capacity allowed (50 cc) for 4-stroke PI engines is too low (lack of torque)because the weight of these vehicles is much higher than 2-wheel mopeds.

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Type 1 - ACEM proposals

cold-warm Weighting Factors

• Keep the current Euro 4 factors for cold-warm weighting.This requires amending Annex II 6.1.1.6.2.2. Table 1-10 ofthe REPPR (134/2014) (replace 50/50 by 30/70)

WMTC for non-L3 vehicles

• Allow choice between R40/R47 or WMTC tests with the Euro 5limits until there is solid evidence that a modified version ofthe WMTC is suitable for testing non-L3 category vehicles.This requires amending Annex IV 1.1.1.4. of 168/2013 andAnnex II 6.1.1.6.2.2. Table 1-10 of the REPPR (134/2014)

Diesel light quadrimobiles (L6e-B) and 3 wheeled utilitymopeds (L2e-U)

• Modify the classification criteria in Annex I Reg. 168/2013 tosupport the use of gasoline engines: Allow up to [XYZ]ccengine capacity for PI engines;

If not: Urgent need to reassess Euro 5 current limit values toavoid collapse of this niche industry in 2020.

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Vehicle

category

Vehicle category

name

Test

CycleEquation #

Weighting

Factors

L1e-A Powered cycle

WMTC

stage 3

2-53

w1 = 0,30

L1e-B Two-wheel moped

w2 = 0,70

L2eThree-wheel

moped

L6e-ALight on-road

Quad

L6e-BLight quadri-

mobile

L3e

L4e

Two-wheel

motorcycle with

and without side-

car

vmax < 130 km/h

2-53

w1 = 0,30

w2 = 0,70L5e-ATricycle

vmax < 130 km/h

L7e-A

Heavy on-road

quad

vmax < 130 km/h