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Document Title CECE-proposed revisions to the draft REC regulation
Reference Number REC-10-05
Date
16 Apr 2012
Summary Proposals from the CECE for revisions to the draft text of the retrofit emissions control devices regulation concerning the articles on operating behavior and safety hazard, noise emissions, and installation of the devices.
Source(s) CECE
Rulemaking Area(s) UN R132 Retrofit Emissions
Meeting(s)
Downloads
UNECE server .pdf format
Excerpts from session reports related to this document
REC | Session 10 | 24-25 Apr 2012

i) CECE proposed text (doc. REC-10-05)

Williams presented his slides based on the CECE proposals, noting that the primary objective of the CECE proposal is to ensure that safety considerations are adequately addressed in the installation of the REC and subsequent operation of the vehicle. Specific references to NRMM have been dropped as under Reg. 96 NRMM are a class of vehicle. The proposals require that written instructions have to be passed from the REC provider to the installer and/or owner to maintain the original level of safety of the vehicle.

Following discussion of the need for adequate information to be provided within the legal limitations of a UN regulation’s applicability, the general approach was agreed, with the detailed text to be discussed under item 6.

ii) OICA/Euromot proposed text

Stein introduced the outline proposed by OICA and Euromot on NOx control provisions (doc. REC-10-06), based upon those adopted for Euro VI and proposed for NRMM Stage IV but adapted for REC. It had not been possible to compile a full text for this meeting, but this will be done for the June REC meeting.

The proposed general requirements and operator inducement system were summarised. It was noted that the text would need to include provision for both electronically- and mechanically-controlled engines. It was also agreed that in the event of the activation of the operator inducement interruption of starter current, there should be a limited emergency over-ride. It was agreed that, with these additions, the requirements as proposed by Euromot/OICA are necessary and that the proposal is accepted. Development of the full text is now needed.

The question of whether there should be equivalent requirements for PM reduction RECs, but after discussion it was agreed that this was not currently feasible or necessary.

iii) AECC information on NOx efficiency vs. driving cycle

May presented some test results on a limited sample of 3 engines showing the lower NOx conversion efficiency over the WHTC compared to the ETC (document REC-10-09). In discussion it was noted that the current generation of SCRT-type systems would not be able to achieve approval to the proposed efficiencies on the weighted WHTC, but they can achieve 70-80% efficiency over the whole-vehicle test using the London Bus (Millbrook) Cycle which appears also to be representative of bus operation in other European cities. It was also commented that bus retrofitting had to be very specific for the duty cycle to get maximum advantage.

The question was asked as to whether this meant that the proposed NOx efficiency for the REC regulation would need to be reduced. It was agreed that the efficiency figures need to be reviewed but they should not be set too low. It was suggested that a conversion factor could be proposed to convert the original proposal (which was based on ETC efficiency) to WHTC figures.

The chairman has initiated some work on this at TNO and this will be followed up.

iv) Comments from Hungary

Uhlik presented Hungary’s comments (doc. REC-10-07) and proposed that with the split into rev.00 and rev.01 versions of the regulation the term Reduction Level is no longer needed as each version would only allow 1 level. However, in later discussion it was agreed that Reduction Level should be retained so that customers can differentiate between systems once rev.01 is introduced.

In discussion of the Hungarian proposal to revise the matrices in section 8 it was agreed that the tables show the emissions levels that have to be achieved by meeting the next emissions level of Reg. 49 or 96; so the figures are thus fixed by those Regulations. The requirement in the draft REC regulation is to meet both this performance level and the Reduction (efficiency) Level. It was suggested that the information document (Annex 1) and Communication (Annex 2) should be modified to show additional information – at least the emissions level achieved as well as the base level.

In regard to Hungary’s point on the clarification of durability requirements, it was agreed that Section 9.1 should be clarified to: “The applicant shall declare confirm that the REC system will comply with the applicable provisions during normal operation over a useful life of:…”. It was also agreed to add a new Section 9.5 to show that the REC must meet the limit values and efficiency requirements at the end of the 1000 hour durability test.

Following from a further Hungarian proposal, the first sentence of Section 10 (application range) was modified to: “The application range is initially limited to describes the range of engines or engine systems to which the REC family may be applied….”

It was also agreed to add a sentence that this paragraph is not applicable to systems intended to meet Euro VI limit values.

The provision allowing the extension of the application range of RECs to other engine manufacturers was also discussed, with the conclusion no further changes were needed.

Hungary also proposed an additional section on recognition of alternative Type Approvals. The proposal was not accepted by the group, but it was noted that the draft Regulation does not preclude using the same engine for an NRMM and an HD approval through full testing to the two sets of requirements.