Exchange of views on draft Informal Document for GRPE. Mr. Dekker, chairman of the HDDF TF (retrofit) presented the status of the draft retrofit regulation. (Document GFV 43-06). Presentation highlights are included below in paragraphs 4-13.
4. The Task Force has had 13 teleconferences and 3 face-to-face meetings.
5. An Informal Document of the regulation is being prepared for submittal by the 14th March 2016. GFV documents 43-04 and 43-05 show the new regulation (05 shows the changes done based on the most recent work).
6. Only Euro V and EEV vehicles are included in the proposed regulation. Though this is a new regulation, it references Regulation 49 (heavy duty engines) throughout the draft.
7. The basic principles of the type approval process, issues and applications of the dual- fuel retrofit systems were presented. There were no questions following this section of the presentation.
8. Emission Tests: Engine test and simplified test. Initial type approval is based on an engine test and a for a type approval extension a simplified test will be prescribed. (Details of the simplified test method is still-to-be-developed and verified.) SEMS systems can be used for type approval extension.
9. Germany raised some questions about allowing testing on a chassis dynamometer and questioned the simplified test procedure. Germany will provide detailed comments and concerns in a written document.
10. Chairman Dekker explained that a back-to-back test option is provided, so long as it is as identical as possible for both gaseous fuels and diesel. Germany responded that chassis dyno testing for HDVs does not exist and has no procedures so recommending it in this proposed regulation may not be able to be validated. It is Germany’s view that an entirely new Global Technical Regulation specifying chassis dyno testing would be needed and this cannot be created within this proposed regulation.
11. The concept of back-to-back testing is a fundamental principle of this regulation. Next to PEMS also chassis dyno testing can be used but must be validated. The issue of chassis dyno testing will remain open for further discussion based on Germany’s remarks.
12. Methane emissions: Two options are provided: 1) emissions limits for D-F mode as specified in R.49; and 2) NOx, NMHC, PM and CO limits in R.49 would apply but methane emissions shall not exceed the GER dependent CH4 limit as: CH4 ≤ 6.84 x GER/100 AND CH4 ≤ 6 [g/kWh].
13. Safety issues: There were OEM concerns about possible torque differences between diesel and dual-fuel operation (physical and/or CAN parameters). A torque test and CAN communication requirement has been specified in the regulation to take these concerns into account.
5. Overview of the drafting work since GFV-43 (Mr. Dekker) (PowerPoint presentation GFV-45-04). This presentation is an adaptation of the one made in GFV-43 (GFV-43-06). The two presentations provide an overview of the new regulation for retrofit systems intended to be fitted on a heavy duty diesel vehicle to enable its operation either in diesel mode or in dual-fuel mode. The regulation includes Euro V and EEV engines.
At GFV-43 concerns were raised by Germany about chassis dynamometer test procedures and by the legal staff of DG-Growth (European Commission) about approval of ‘non-compliant diesel engines’. DG Growth was concerned about language specifying the possibility to perform retrofit system type approval on a non-compliant demonstration engine (even when the retrofitted engine would be compliant on DF operation). Germany requested that the simplified engine test bench (ESC only) and chassis dyno tests and provisions for increased CO emissions be removed.