Mr. Piccolo reminds the group that Mr. Radzimirski (Poland), in the GRPE January session and in subsequent documents circulated to the group, made two main remarks:

• ● As for R.115 proposed amendments, several retrofit system manufacturers find it difficult to meet the emission limit in R.115 because of a certain incapacity to correctly calibrate the engine on gas or, for example, on CNG because of the ineffectiveness of the catalyst. If the possibility to use petrol up to 20% in energy unit was accepted, it would be possible for such manufacturers to extend the operation with petrol in the gas mode after the cold start for some 200 – 250 seconds in a Type I test, in order to satisfy the requirements. As for petrol direct injection engines, that would not be possible since petrol use is mainly required in the second part of the cycle. Mr. Radzimirski proposes, therefore, to limit this provision only to vehicles with direct injection petrol engines.

• ● As for both proposed amendments to R.115 and R. 83, the proposed method for gas ratio calculation (Annex 6B) does not seem to be suitable for reference CNG fuel G25 that is composed of 86% mole of methane and 14% mole of nitrogen (average percentage). The measured CNG mass consumed during the cycle by fuel weighing (numerator of the gas energy ratio) would correspond to the total mass of methane and nitrogen, while the denominator would estimate only the equivalent mass of methane consumed during the cycle. In the case of G 25 reference gas, the calculated gas energy ratio would, therefore, be higher than the actual one. Therefore, the method for G25 needs correcting via, for example, a correction coefficient.

As for the first remark, Mr Piccolo stated that AEGPL shared the concern of Mr Radzimirski and, in principle, would keep the two regulations aligned. However, if the group agrees such a “decoupling” of the two proposals making R.115 more restrictive in comparison with R 83, AEGPL would not oppose it.

Regarding Mr Radzimirski’s second remark, AEGPL asks the group and, in particular, NGVA Europe to specify some correction factors to the gas energy ratio in the case of testing with G25.

Mr. Del Alamo (NGVA Europe) indicated that Fiat does not see the necessity of the amendment to R 83.

Mr. Tappe (CLEPA/Bosch) suggested to leave to the discretion of the OEM’s the opportunity to use the two fuels, gas and petrol, in the most synergistic way for any type of engine system, be it a PSI or GDI. This is in line with a request for more flexibility made by OEM suppliers. OEMs, to respect the CO2 obligations, are forced to minimize the use of petrol and have no reason to misuse of petrol to fulfil the emission limits in the gas mode. That said, due to some safety concerns about the gas mass measurement by weighing, Mr Tappe asked the group to evaluate a different method based on petrol and gas ECU’s data, validated by a proper initial comparison with the official results coming from the application of FC (carbon balance) formulae.

Mr. Castagnini (AEB) expressed concern that a change of this type would delay submitting the formal document. Hence, he suggests to add the new method proposed by CLEPA as an alternative.

My Rijnders, taking into account the positions of the members, proposed to convert the present R.83 proposal (GRPE-63-05-Rev.1) into a formal document for the next GRPE session with no modifications. As for the R.115 proposal, the formal document based on the informal GRPE-63-06-Rev.1 will reflect the comment received by the Polish expert, in restricting the scope of the provision related to the 80% minimum limit for gas energy ratio only to vehicles with petrol direct injection engines. In addition, Mr. Rijnders asked Mr Tappe to provide an appropriate text containing provisions for an alternative method to weighing the mass of gas. This could possibly be included in an informal document to be submitted to the June 2012 GRPE by GFV.

Furthermore, it is agreed that an adequate correction factor for G25 will be part of an informal document for the next GRPE session.

The group agrees and provide for a consistent revision of GRPE-63-06-Rev.1.

16. Mr. Rijnders informed the group that the changes to Regulation 83 and Regulation 115 were approved by the GRPE. The Technical Committee for Motor Vehicles (TCMV) in Brussels will vote on this regulation next week to mandate the Commission to vote positively in WP.29 in November 2012.

17. The new proposal tabled by CLEPA (GFV-22-02) represents an updated version of the document GFV-20-03 that was presented by Harry Scheule (Continental/CLEPA) and discussed at the last GFV in Bologna, 14-15 May 2012. Winfried Langer (CLEPA/Bosch) introduced the new document: since the weighing-of-gas-tank procedure, which the current amendments are based on, may, from CLEPA’s viewpoint, raise practical and safety problems during development and type approval. An alternative method is proposed for the identification of gas fuel mass as calculated by the ECU, making use of the injection time and flow rate through the fuel injectors,

18. Ms. Leifheit (ACEA/VW) said that she has not had a chance to check this alternative approach with her colleagues. She would have preferred to see the document earlier, therefore, they cannot make any comments but it looks very promising.

19. Mr. Del Alamo (NGVAE) also indicates that the document looks very good but that some more time is needed to review the proposal.

20. Mr. Piccolo (AEGPL) agrees that, even if based on proprietary data, the use of ECU outputs is undoubtedly more ‘elegant’ than the weighing procedure, and, if accepted by the authorities, it would be a valuable alternative to gas tank weighing, that could still be the method in the event of a dispute.

21. Mr. Dekker sees some potential problems regarding 2% accuracy measuring CO2. The 2% error in CO2 can mean a 10% error in petrol consumption in percentage. The proposed validation procedure of ECU data needs further investigation and, furthermore, a detailed legal text about this process must be included in the regulation. The advantage of the weighing method is that it can be checked. So, additional work has to be done to get a consistent proposal.

22. As regards the errors, Mr. Langer points out that 2% error in the petrol mass would imply a 2% error in the CO2 by calculation.

23. Mr. Rijnders understands that the work of the OEM can be accurate, but from the regulator’s view as a type approval procedure they have to be able to check.

24. Mr. Rijnders indicates that we must wait for OICA/ACEA’s response. He suggests that by December the GFV members should make comments in a written paper so the issue can be discussed again in January 2013. He asks CLEPA to prepare in detail, in the next two-three weeks, two informal documents (both R. 83 and R. 115) for the GRPE January 2013 session, possibly taking into account the comments expressed today. These informal documents will be sent to the GFV members before the end of October for consideration. Deadline for comments from GFV members must be provided by the end of November/early December Thereafter CLEPA will try to revise their proposals in accordance with the collected comments. If needed, a possible telephone conference can be arranged in December among GFV members in advance of the January 2013 GFV. Otherwise, the final drafts will be dealt with directly in the January 2013 GFV.